Personal Data Processing Policy

General provisions

This Policy describes how LIMITED LIABILITY COMPANY "QUBITRINO TECHNOLOGIES" (OGRN (primary state registration number) 1265000018755, INN (taxpayer identification number) 5050171000; hereinafter, the Operator) processes the personal data of users of the Qubitrino service on the qubitrinotech.ru website.
The Policy has been drawn up in accordance with Federal Law No. 152-FZ "On Personal Data" of 27 July 2006.
The Policy is publicly available on this page.

What data is processed

• email address and/or phone number, for signing in with a one-time code;
• information from the trading terminal reports uploaded by the user: trades, instruments, volumes, prices, time, result, as well as the account number and name if they appear in the report;
• daily check-ins, rules and texts that the user enters;
• information about the plan and payments: amount, date, status (the Operator does not receive bank card data);
• technical data: IP address, browser data, session cookies, sign-in time.

The Operator does not process special categories of personal data or biometric personal data.

Purposes of processing

• signing in to the Service and protecting the account;
• providing the features of the Service: calculating metrics, keeping rules and check-ins, reviewing trades;
• arranging and recording paid plans;
• responding to user requests;
• ensuring the security and proper operation of the Service.

Legal grounds

• the user's consent to the processing of personal data;
• performance of the Terms of Service to which the user is a party;
• performance of the Operator's obligations established by law.

How the data is processed

The data is processed using automated means: collection, recording, systematization, accumulation, storage, clarification, retrieval, use, depersonalization, blocking, deletion and destruction.
The data is stored and processed on servers located in the Russian Federation. Recording, systematization, accumulation, storage, clarification and retrieval of the personal data of citizens of the Russian Federation are carried out using databases located in the Russian Federation.
The primary AI provider is DeepSeek V4.1 Flash through Reg.cloud. Under Reg.cloud's terms for models running on its own infrastructure, requests and responses are not logged or used to train AI, and data does not leave the Reg.cloud perimeter. This AI review processing route is performed in the Russian Federation.
When the external DeepSeek API is enabled manually, only calculated trade metrics, rules and user-entered texts are sent for AI review, without names, account numbers, brokers or contact details. This transfer is performed outside the Russian Federation. No automatic failover to external providers is used after a failure.
Cross-border transfer of personal data occurs only when the external AI provider is enabled manually by the superuser.

Who receives the data

• the telecom operator and the email service: the email address or phone number, to deliver the one-time code;
• the payment partner: the information required to process the payment for a plan;
• government authorities: in cases provided for by law.

Personal data is not sold and is not transferred to third parties for advertising.

Retention periods

The data is kept while the user's account exists and is deleted within 30 days after the account is deleted or the consent is withdrawn, unless the law requires it to be kept longer.
Payment information is kept for the periods established by accounting legislation.

Data protection

The Operator takes legal, organizational and technical protection measures: encrypted connections, restricted access to data, storing one-time codes as hashes, access logging and backups.

User rights

The user has the right to obtain information about the processing of their data, to demand its clarification, blocking or destruction, to withdraw the consent to processing, and to appeal against the Operator's actions to Roskomnadzor or in court.
Requests are sent to info@qubitrinotech.ru. The Operator responds within 10 business days of receiving a request.

Cookies

The Service uses only necessary cookies: for the sign-in session and form protection. Third-party advertising and analytics cookies are not used.

Website analytics

The site uses Yandex.Metrika (Yandex LLC) for audience measurement: cookies and anonymized page-view statistics; session recording runs on public pages only and is disabled in the personal account.

Changes to the Policy

The Operator may change the Policy. A new edition takes effect from the moment it is published on this page.

Operator contacts

• LIMITED LIABILITY COMPANY "QUBITRINO TECHNOLOGIES"
• OGRN 1265000018755, INN 5050171000, KPP (tax registration reason code) 505001001
• Address: 8 Pushkina Street, apt. 166, Losino-Petrovsky, Losino-Petrovsky urban district, Moscow Region, 141151, Russian Federation
• Email: info@qubitrinotech.ru
• Phone: +7 901 900-80-80