PRIVACY POLICY

Sole Proprietor Aleynikova Irina Timofeevna

TIN (INN): 614531729391

OGRNIP: 304614512000035

Address: 346330, Rostov Region, Donetsk, 60 Kvartal St., bldg. 9, apt. 3

Effective date: 25 August 2026

1. General provisions

1.1. This Privacy Policy (hereinafter the "Policy") sets out the procedure for

the processing and protection of the personal data of users of the Sportedge service (hereinafter the "Service"), available at sportedge-ai.ru and through the Telegram bot @sportedge_ai_bot

1.2. The personal data operator is Sole Proprietor Aleynikova Irina Timofeevna (hereinafter the "Operator").

1.3. By using the Service, you confirm your acceptance of the terms of this Policy.

If you do not agree with these terms, please stop using the Service.

2. What data we collect

2.1. When you use the Service, we may collect the following categories of personal data:

• Telegram ID - the unique identifier of your Telegram account;
• Username - if it is set in your Telegram settings;
• Date and time of subscription activation;
• Payment information - transaction data (amount, date, payment status) processed through payment systems (T-Bank, SBP and others);
• Technical information - IP address, device type, browser version (when visiting the website).

2.2. We do not collect or store bank card details. All payments are handled by certified payment systems (T-Bank and others) that comply with the

PCI DSS standard.

3. Purposes of personal data processing

3.1. Personal data is processed solely for the following purposes:

• Providing access to the functionality of the Service (sending notifications about

odds movements);

• Identifying the user and managing the subscription;
• Processing payments and issuing invoices;
• Technical support and communication with users;
• Compliance with the requirements of the legislation of the Russian Federation.

3.2. We do not use your data to send third-party advertising without your explicit consent.

4. Legal grounds for processing

4.1. Personal data is processed on the following grounds:

• Your voluntary consent (Art. 9 of Federal Law No. 152-FZ "On

Personal Data");

• The necessity of performing the contract (Public Offer) to which you are a party;
• The legitimate interests of the Operator (ensuring security, preventing fraud).

5. Disclosure to third parties5.1. We do not sell or disclose your personal data to third parties, except

in the following cases:

• Payment systems (T-Bank, SBP) - to process transactions;
• Telegram API - to deliver notifications through the bot;
• Government authorities - upon official request under the legislation of the Russian Federation.

5.2. All third parties are required to maintain the confidentiality and security of your

data.

6. Storage and protection of data

6.1. Personal data is stored on secure servers using

modern encryption methods (SSL/TLS).

6.2. Data retention periods:

• Active subscription - for the entire period during which the Service is used;
• After cancellation of the subscription - data is deleted within 30 days, with the exception of information required for accounting purposes (retained for 5 years in accordance with the legislation of the Russian Federation).

6.3. We apply organisational and technical measures to protect data against unauthorised access, loss or alteration.

7. Your rights

7.1. You have the right to:

• Request access to your personal data;
• Correct inaccurate data;
• Delete your data (the right to be forgotten) - except where retention is required by law;
• Withdraw your consent to data processing at any time;
• Lodge a complaint with Roskomnadzor if your rights have been violated.

7.2. To exercise your rights, contact us at info@sportedge-ai.ru

8. Use of cookies

8.1. The Sportedge website uses cookies to improve the operation of the service (remembering the display theme, visit analytics).

8.2. You may disable cookies in your browser settings, however this may limit the functionality of the website.

9. Changes to this Policy

9.1. The Operator reserves the right to make changes to this Policy.

The current version is always available at sportedge-ai.ru

9.2. Continued use of the Service after changes have been made constitutes your acceptance of the new version of the Policy.

10. Contact information

For all questions relating to the processing of personal data, please contact:

Sole Proprietor Aleynikova Irina Timofeevna

Address: 346330, Rostov Region, Donetsk, 60 Kvartal St., bldg. 9, apt. 3

(c) 2026 sportedge-ai All rights reserved.