NOMIO.
PRIVACY AND PERSONAL DATA PROCESSING POLICY
For nomio.pro, the official Nomio Telegram bot, payment forms, support channels, and related services



1. General provisions1.1. This Policy sets out how the Individual Entrepreneur Mokobo Krist Lyudvikovich (the “Controller”) processes personal data in connection with nomio.pro, the official Nomio Telegram bot, contact forms, payment pages, support, educational, organisational, information, and AI-enabled services.
1.2. The Policy is prepared under the Constitution of the Russian Federation, Federal Law No. 152-FZ “On Personal Data”, Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection”, the Russian Consumer Protection Law, and other applicable mandatory rules.
1.3. It applies to website visitors, bot users, applicants, customers, payers, service beneficiaries, representatives, family members, and other persons whose data is lawfully provided to Nomio.
1.4. A user who disagrees with this Policy should not use functions that require personal data. Public pages may remain available subject to rules on strictly necessary cookies.
2.2. The Controller determines the purposes and means of processing unless a third party is expressly identified as an independent controller for a particular operation.
3. Scope·         Nomio website, forms, shopping cart, payment, Success and Fail pages;
·         official Telegram bot and support correspondence;
·         free and paid guides, consultations, coordination, lessons, document review, and Nomio AI access;
·         e-mail, telephone, and approved messenger communications;
·         documents and facts reasonably required for the selected package.
3.2. This Policy does not govern independent processing by banks, payment providers, Telegram, universities, clinics, insurers, government bodies, or partners where the user deals with them directly or enters into a separate agreement.
4. Principles and legal grounds·         lawfulness, fairness, and transparency;
·         specific and legitimate purposes;
·         data minimisation and avoidance of excessive collection;
·         accuracy and reasonable updating;
·         retention only as long as needed for the purpose or required by law;
·         confidentiality and proportionate legal, organisational, and technical safeguards.
4.2. Depending on the circumstances, processing is based on consent; steps requested before contract formation; performance of a contract; compliance with legal obligations; protection of legitimate rights and interests without overriding the data subject’s rights; or another basis permitted by law.
4.3. Optional data is provided voluntarily. Refusal to provide optional data does not restrict the core service. Where specific data is objectively necessary, Nomio explains this before collection.
5.2. Nomio does not receive or store the full card number, CVC/CVV, or other payment credentials entered on the payment provider’s secure page. Nomio receives only order, amount, status, and transaction identifiers needed for accounting, receipts, refunds, and disputes.
5.3. Nomio does not request biometric data and does not use facial images for biometric identification.
6.2. These are maximum operational guidelines. Data may be deleted earlier when the purpose is achieved or kept longer where tax, accounting, procedural law, or an unresolved dispute requires it.
7. Sources and collection·         directly from the data subject through forms, the bot, e-mail, telephone, lessons, and support;
·         from a payer or lawful representative acting for a beneficiary;
·         from service partners where lawful and necessary;
·         automatically through website and system logs;
·         from public sources only where appropriate and lawful.
7.2. A person providing another adult’s data must have a lawful basis. Nomio may suspend processing and request the adult’s own consent. A legal representative’s authority may be verified.
8. Processing operations8.1. Nomio may collect, record, organise, accumulate, store, update, retrieve, use, compare, provide access, transfer to a specified recipient, anonymise, block, delete, and destroy data by automated and non-automated means.
8.2. Nomio does not make personal data publicly available. Publication of a review, photograph, or identifiable story requires a separate consent for dissemination.
8.3. Nomio does not sell personal data or disclose it to an unlimited group for independent marketing.
9.2. A processor acting on Nomio’s instructions is contractually required to maintain confidentiality, security, purpose limitation, and deletion/return after the instruction ends.
9.3. When a user independently visits a partner’s website or contracts directly, that partner acts as an independent controller.
10. Artificial intelligence·         Nomio uses AI to draft answers, translations, checklists, routes, and other service materials;
·         full passports, visas, health records, card details, and other sensitive files are not sent to an external AI provider by default;
·         where possible, identifiers are removed or replaced before an AI request;
·         users must use designated document-review channels rather than the ordinary AI chat;
·         AI output is reviewed by a human when the paid package expressly includes human review.
10.2. A request may be sent to a foreign AI provider only after applicable cross-border requirements are addressed and only to the extent necessary for the function.
11. Data localisation and cross-border transfers11.1. When collecting personal data of Russian citizens through the Internet, the Controller uses databases located in the Russian Federation for recording, systematisation, accumulation, storage, updating, and retrieval, except where a statutory exception applies.
11.2. Telegram, foreign AI providers, and some technical services may involve cross-border transfers. Before such transfers, Nomio takes the actions required by Russian law, including regulatory notification, recipient assessment, and consent where required.
11.3. If lawful cross-border processing cannot be ensured for a function, Nomio restricts the function, offers an alternative channel, or does not accept sensitive data through it.
12.2. Refusal of optional cookies must not block the website’s core functions.
13. Children and family members13.1. A service for a minor is ordered by a parent or legal representative. Nomio may request proof of authority and a separate representative consent.
13.2. An adult family member gives consent independently. A buyer may not submit adult relatives’, friends’, classmates’, or other persons’ documents without a lawful basis.
13.3. Documents Plus covers only the subscriber and up to three pre-declared close relatives: spouse, children, or parents. Separate consent remains necessary for each adult.
14. Special categories of data14.1. Health information is a special category of personal data and is processed only on a legal basis, normally separate written consent.
14.2. An ordinary website checkbox is not used as the sole basis for health-data processing. Before submission, the user signs the separate paper or legally valid electronic form in Appendix 3 to the Consent document.
14.3. Medical records must not be sent through an ordinary Tilda form or the general AI chat. Nomio provides a designated channel and identifies the persons who may access the data.
14.4. Nomio does not provide medical care and does not use health information to diagnose or prescribe treatment.
15. Retention, termination, and destruction15.1. Data is retained no longer than required for the purpose, contract, or law. It is then deleted, destroyed, or anonymised unless further retention is legally required or needed to protect the parties’ rights.
15.2. After withdrawal of consent, consent-based processing stops and the relevant data is destroyed within the statutory period, generally no later than 30 days, unless another lawful basis remains.
15.3. Inaccurate data is corrected; unlawfully obtained or unnecessary data is blocked and destroyed according to law. Destruction is documented where required.
16. Security measures·         appointment of a person responsible for personal data;
·         access control and least-privilege permissions;
·         confidentiality obligations and contractor controls;
·         secure transmission, account protection, logging, and backups where appropriate;
·         incident response, periodic review, and deletion procedures;
·         separation of ordinary support channels from sensitive-document channels.
16.2. No transmission or storage method is absolutely secure. Users should not send sensitive data through unsuitable channels.
17. Data-subject rights·         obtain confirmation and information about processing;
·         access personal data, subject to lawful limitations;
·         request correction, blocking, deletion, or destruction;
·         withdraw consent;
·         object where the law provides that right;
·         refuse direct marketing;
·         complain to Roskomnadzor or a competent court;
·         exercise other non-waivable rights under applicable law.
18. Requests and withdrawal18.1. Requests are sent to christ@antogi.ru with “Personal Data” in the subject line. Nomio may ask for the name, contact, order number, or other proportionate information confirming identity and the relationship with Nomio, avoiding unnecessary passport copies.
18.2. Information on processing is provided within the period required by law. The standard Russian-law period is ten business days, subject to a reasoned statutory extension where permitted.
18.3. Withdrawal does not affect processing already lawfully performed and does not end processing required for legal compliance, fiscal records, completion of calculations, or defence of claims.
19. Changes to this Policy19.1. Nomio may update this Policy when law, services, data categories, or providers change. The new version applies from publication unless a later date is stated. Material changes may be additionally notified through the website or bot.
Effective date: 15 July 2026. Version 1.0.