Personal Data Processing Policy
The “ЖИЗНЬ” (Time to Live) service: iOS mobile app and website https://timetolive.app
Version v1 of 31 October 2026. The Russian text prevails. Published at https://timetolive.app/en/privacy in accordance with Part 2, Art. 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law”).
1. General provisions
1.1. This Policy defines what personal data the operator processes in running the “ЖИЗНЬ” service, for what purposes and on what grounds, how the data is protected, and how personal data subjects can exercise their rights.
1.2. This Policy applies to all personal data the operator receives from app users, visitors to the website https://timetolive.app, and persons who contact the operator.
1.3. Terms are used in the meanings established by Art. 3 of the Law.
1.4. Consent to the processing of personal data is set out in a separate document (https://timetolive.app/en/consent) and is not part of this Policy.
2. Operator
| Operator | Sole proprietor Emelianov Oleg Anatolievich |
| INN | 312822499408 |
| OGRNIP | 319312300015628 |
| Address | Stary Oskol, Belgorod Region, 309516, Russia |
| Person responsible for organizing personal data processing | Sole proprietor Emelianov Oleg Anatolievich |
| Address for personal data requests | privacy@timetolive.app |
3. Processing principles
The operator processes personal data lawfully and fairly; only for purposes defined in advance; only to the extent necessary for those purposes; does not combine databases with incompatible purposes; ensures the data is accurate and up to date; stores data no longer than the purposes require, and destroys it once the purposes are achieved or when there is no longer a need to achieve them (Art. 5 of the Law).
4. Whose data, what data, why and on what basis
4.1. App users
| Purpose | Data | Legal basis | Period |
|---|---|---|---|
| Account, sign-in and protection against abuse | account and device identifiers, App Attest key, access tokens, Apple ID identifier and email address (only when signing in with Apple), time zone, language, app and OS version, date of the device’s last activity | performance of the user agreement (clause 5, Part 1, Art. 6 of the Law), consent (clause 1, Part 1, Art. 6) | until the account is deleted or consent is withdrawn |
| Creating personal stories, affirmations and voiceover | name (optional), form of address, selected areas of life, texts of wishes and details (place, people nearby, desired feelings), created stories, affirmations and audio, voice and narration settings | consent (clause 1, Part 1, Art. 6 of the Law) | until deleted by the user, the account is deleted or consent is withdrawn |
| Library and listening | favorites, playlists, listening position | consent | until the account is deleted or consent is withdrawn |
| Notifications | push notification token, delivery time | consent | until notifications are turned off, the account is deleted or consent is withdrawn |
| Service improvement and analytics | app usage events without texts, country (determined from the IP address; the IP address itself is not stored) | consent | 13 months |
| Content safety: review of automatically blocked wishes and of complaints about stories | text of the wish or story without name and contact details, blocking category, moderator’s decision; for a complaint, the complainant’s account identifier | consent; rights and legitimate interests of the operator (clause 7, Part 1, Art. 6 of the Law) | until the moderator’s decision, then for the story’s retention period |
| Proof of consent | account identifier, document, version, date and method of consent or its withdrawal, app version | performance of the operator’s duty to prove that consent was obtained (Part 3, Art. 9 of the Law) | 3 years after consent is withdrawn or processing ends: a period set by the operator with regard to the general limitation period (Art. 196 of the Civil Code of the Russian Federation) |
4.2. Website visitors
| Purpose | Data | Legal basis | Period |
|---|---|---|---|
| Tracking of visits and visitor sources | identifier in the zid cookie, visit identifier, page address, referral source (UTM tags, domain of the referring website), country from the IP address (the IP address is not stored), family of the operating system and browser | consent given in the cookie banner | cookie: 180 days from the last visit; events: 13 months |
| Newsletter with news and new stories, no more than once a month | email address, language, date and version of consent | consent to the newsletter (https://timetolive.app/en/consent/newsletter) | until unsubscribing; after that, the address is deleted within 30 days |
4.3. Buyers of access on the website
Payment on the website is not open yet: this processing will begin when it opens.
| Purpose | Data | Legal basis | Period |
|---|---|---|---|
| Payment for access and opening it for the account, auto-renewal by consent, refunds | account identifier, email address, plan, amount, dates of payments and of the access period, payment identifier at the provider, card binding identifier (token), last four digits of the card, payment system; the operator does not receive the card number, expiry date or CVV/CVC code | performance of the offer agreement (clause 5, Part 1, Art. 6 of the Law); auto-renewal: separate consent (https://timetolive.app/en/consent/recurring) | until access ends and auto-renewal is cancelled; payment records: 5 years after the reporting year (Art. 29 of Federal Law No. 402-FZ “On Accounting”), after the account is deleted, without any link to its contents |
| Cash receipt | email address or phone number for the receipt, items purchased, amount | performance of the duty under Federal Law No. 54-FZ (clause 2, Part 1, Art. 6 of the Law) | 5 years after the reporting year, like payment records (Art. 29 of Federal Law No. 402-FZ); the receipt is generated and transmitted under Federal Law No. 54-FZ |
| Reminders of charges and payment messages | email address, date and amount of the next charge | performance of the offer agreement | until auto-renewal is cancelled |
4.4. Persons who contact the operator
| Purpose | Data | Legal basis | Period |
|---|---|---|---|
| Responding to inquiries and considering data subject requests | email address, name (if given), text of the inquiry, account identifier (if given) | performance of the operator’s duties (clause 2, Part 1, Art. 6 of the Law); rights and legitimate interests of the operator (clause 7, Part 1, Art. 6) | 1 year after the response |
4.5. Special categories of personal data (information about health, intimate life, religious or philosophical beliefs, and others listed in Part 1, Art. 10 of the Law) are not purposefully collected by the operator. The “Health” area is about wellbeing and energy, without diagnoses: please do not enter diagnoses or other such information in the texts of wishes. If a user enters them anyway, they are used only to create the story the user requested and can be deleted together with the wish and the story in the app.
4.6. Biometric personal data is not processed by the operator. The user’s voice is not recorded or stored: dictation of a wish is recognized on the device using iOS tools.
4.7. The service is intended for persons over 18. The operator does not knowingly process data of persons under 18 and deletes it if it becomes aware of such processing.
5. Actions with data and processing methods
5.1. The operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.
5.2. Processing is automated, with transmission over the Internet information and telecommunications network.
5.3. Decisions that have legal consequences for the user or otherwise affect the user’s rights and legitimate interests are not made solely on the basis of automated processing (Art. 16 of the Law). Stories and affirmations are created using artificial intelligence technologies at the user’s request and are artistic in nature.
6. Storage and localization
6.1. The recording, systematization, accumulation, storage, clarification and retrieval of personal data of citizens of the Russian Federation are carried out using databases located in the territory of the Russian Federation (Part 5, Art. 18 of the Law): a server in Moscow and file storage in Russia.
6.2. User texts are stored in encrypted form.
6.3. When the purposes of processing are achieved, when an account is deleted or when consent is withdrawn, personal data is destroyed within 24 hours from production systems and no later than 30 days from backups, unless otherwise provided by law.
7. Transfer to third parties and entrusting processing
7.1. The operator transfers personal data only to the extent necessary for the purposes of processing:
| Who | Why | What they receive | Where |
|---|---|---|---|
| Alex Group LLC (ООО «Алекс Групп», KVMka hosting), INN 5040109853, address: office 322, 1 Sovetskaya St., Bykovo work settlement, Ramenskoye, Moscow Region, 140150, Russia | hosting of the operator’s servers | access to the servers on which the data is stored (without access to the contents) | Russia, Moscow; transit proxy: Netherlands (forwards the encrypted connection to Inworld AI; contents are not accessible and not stored) |
| Beget LLC (ООО «Бегет»), INN 7801451618, address: office 726A, 8B Karla Faberzhe Square, Saint Petersburg, 195112, Russia | storage of audio files, covers, exports and backups | encrypted files | Russia |
| the clickplus service (St. Petersburg) — intermediary for requests to AI models; access supplier Veai — IITECH LLC (ООО «ИИТЕХ»), OGRN 1257700447894, INN 9718287451, address: premises 6/2, 9 bldg. 1 Montazhnaya St., Moscow, 107497, Russia; models: Anthropic, PBC and OpenAI, L.L.C. A no-retention mode is not guaranteed at these intermediaries and suppliers | creating the texts of stories and affirmations | text of the wish and details, selected areas of life, form of address, language, story length, name — only if it is needed for the story | Russia (clickplus, Veai), USA (models) |
| Theai, Inc. (Inworld AI) | story voiceover | story text | USA |
| Apple Inc. | Sign in with Apple, push notifications | device token and notification text; sign-in data are processed by Apple as an independent operator under its own policy | USA |
| Beget LLC (ООО «Бегет»), INN 7801451618, address: office 726A, 8B Karla Faberzhe Square, Saint Petersburg, 195112, Russia | the support@, privacy@ and security@timetolive.app mailboxes: receiving inquiries and replying to them | email address, name (if provided), text of the inquiry | Russia |
| An email provider for the newsletter and payment emails. Such emails are not being sent yet; the provider will be named here before sending starts | subscription confirmation emails and the newsletter; payment emails and reminders of charges | email address, email text | Russia |
| ROBOKASSA LLC (ООО «РОБОКАССА»), INN 5047063929, OGRN 1055009302215, address: room 15A, premises III, 31 bldg. 1 Iskry Street, Moscow, 129344, Russia (the Robokassa service) | accepting payment, storing the card binding for auto-renewal, refunds | card data is entered by the user on the provider’s page and is not transferred to the operator; the operator transfers the amount, purchase description, order identifier and address for the receipt | Russia |
| ROBOKASSA LLC (the “Robocheki” service, details in the row above); the fiscal data operator with which a contract is concluded within the Robokassa service | generating and sending cash receipts (54-FZ) | email address or phone number for the receipt, items purchased, amount | Russia |
7.2. Account identifiers, email address and Apple ID are not transferred to the recipients listed in clause 7.1 for creating texts and voiceover.
7.3. The operator does not sell personal data, does not transfer it for advertising, and does not use it for tracking across apps.
8. Cross-border transfer
8.1. Cross-border transfer is made to the USA (via the clickplus service and supplier Veai to the AI model providers Anthropic and OpenAI; Inworld AI, in transit via the operator’s proxy in the Netherlands; Apple), only with the user’s separate consent (https://timetolive.app/en/consent/cross-border) and after notifying Roskomnadzor (Art. 12 of the Law).
8.2. Without consent to cross-border transfer, creating new stories and push notifications are unavailable; stories created earlier remain available.
9. Cookies
The website uses one first-party cookie to track visits, only after the visitor’s consent. Details: https://timetolive.app/en/cookies. The app does not use cookies.
10. Protection measures
The operator takes legal, organizational and technical measures under Arts. 18.1 and 19 of the Law, including:
- a person responsible for organizing personal data processing has been appointed, local acts have been approved, and internal control is carried out;
- the security level of the information system has been determined, and measures established by the Government of the Russian Federation and FSTEC of Russia are applied;
- data is transmitted only over secure protocols (TLS); user texts and backups are stored in encrypted form;
- access to data is limited to authorized persons by role, with sign-in by passkeys and logging of actions;
- user texts are not used in analytics and are not written to system logs;
- incidents are monitored and responded to, including notifying Roskomnadzor within the periods established by Part 3.1, Art. 21 of the Law.
11. Rights of the personal data subject
11.1. The data subject has the right to:
- receive information about the processing of their personal data (Art. 14 of the Law);
- demand that data be clarified, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose;
- withdraw consent to processing;
- appeal against the operator’s actions to Roskomnadzor or in court.
11.2. How to exercise these rights:
- in the app: “Profile” → “Export data” (a copy of all data, the archive is available for 7 days), “Delete account”, “Withdraw consent”, deleting individual wishes and stories;
- by email to privacy@timetolive.app from the account’s email address (when signed in with Apple). If the account is not linked to Apple, the operator cannot identify it from an email: all these actions are available in the app.
11.3. The operator responds to a request within 10 working days of receipt. This period may be extended by no more than 5 working days by sending a reasoned notice (Part 3, Art. 14, Art. 20 of the Law).
11.4. When consent is withdrawn, the operator stops processing and destroys the data within a period not exceeding 30 days (Part 5, Art. 21 of the Law), unless it has another lawful basis for processing. In practice, data is deleted from production systems within 24 hours and from backups no later than 30 days (clause 6.3).
11.5. Auto-renewal of access purchased on the website is cancelled automatically when the account is deleted; payment records are kept for the periods in clause 4.3 without any link to the account’s contents.
12. Changes to the Policy
The operator may change this Policy. A new version is published at https://timetolive.app/en/privacy with its date indicated. If the changes require new consent, the app will request it separately.
13. Contacts
Questions about personal data processing: privacy@timetolive.app. The authorized body for the protection of the rights of personal data subjects is the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor), https://rkn.gov.ru.