Made on
Tilda
Publication date: 24 September 2026
Effective date: 24 September 2026
Version: v.2.3 (of 24 September 2026)
This is an English translation. In case of any discrepancy, the Russian version published at https://promoos.tech/privacy prevails.
1.1. This Privacy and Personal Data Processing Policy (the “Policy”) forms an integral part of the Public Offer (Agreement) for the use of the PromoOS Service, published at https://promoos.tech/en/terms.
1.2. The Policy sets out the procedure for processing and protecting information about Users and visitors of the Site, including personal data, which the Company receives in connection with the use of the Service and the Site, and is the document defining the Company’s policy as an operator (holder of a data array) of personal data.
1.3. Users’ personal data are processed on the basis of a separate Consent to the Processing of Personal Data (https://promoos.tech/en/consent), which the User gives when registering an Account, as well as on the other grounds specified in Section 5. Reading this Policy does not in itself constitute consent to the processing of personal data.
1.4. If the User does not agree with the Policy, the User may refrain from giving consent to the processing of personal data and from using the Service, or may delete the Account.
2.1. Company (Operator) means Limited Liability Company «PromoOS» (OsOO «Promoos», «PromoOS» LLC), registration number 329936-3301-ООО, TIN (INN) 00906202610151, OKPO 34999498, registered address: 64b Erkindik Avenue, Pervomaisky District, Bishkek, Kyrgyz Republic.
2.2. Service means the PromoOS software available at https://account.promoos.tech, which provides the ability to generate content using artificial intelligence technologies.
2.3. Site means the Company’s website at https://promoos.tech, including all of its pages and subdomains.
2.4. User means an individual who has registered an Account and/or uses the Service, or an authorised representative of a legal entity.
2.5. Personal data means any information relating to a directly or indirectly identified or identifiable individual (personal data subject).
2.6. Content means the results generated by the Service at the User’s request, including text, images, video, avatars, content plans and analytical reports.
2.7. Account means the User’s account in the Service.
2.8. Processing of personal data means any action or set of actions performed with personal data, whether or not by automated means.
2.9. Biometric personal data means information characterising the physiological and biological features of a person on the basis of which that person’s identity can be established (including a facial image and voice), and which is used by the operator to establish the identity of the personal data subject.
3.1. Data provided by the User
3.1.1. When registering an Account, the User provides:
3.1.1.1. The User may additionally specify a name in the profile.
3.1.2. In the course of using the Service, the User may provide:
3.1.2.1. The questionnaire describes the business and its audience in general, not specific individuals. The User must not enter personal data of third parties into the questionnaire and prompts without a lawful basis.
3.1.3. When contacting the support service, the User provides the content of the request and any attached files.
3.1.4. Social media accounts (Connected Accounts) are connected through the Ayrshare service (Neverminds Solution LLC, USA). Access keys to Connected Accounts are stored by Ayrshare. The Company receives and stores the publishing profile identifier, the names of the connected accounts, and the statuses and statistics of publications.
3.2. Data collected automatically
3.2.1. The Company automatically collects the following technical data:
3.2.2. The Company automatically collects the following data on the use of the Service:
3.3. Payment data
The Company does not process or store full bank card data. Payment details are transmitted directly to the payment partner (Lava.top) and other payment partners indicated on the Site. The Company receives only the payment confirmation, the transaction identifier, the last 4 digits of the card (for card payments), the currency and the amount. For payments in Telegram Stars, the Company receives from Telegram the payment identifier, the number of Stars and the Telegram user identifier.
3.4. Facial images and voice recordings
3.4.1. In the course of using the Service, the User may upload facial images (to create AI avatars) and voice audio recordings (to create a voice clone).
3.4.2. The Company processes such data solely to generate the Content requested by the User, on the basis of a separate Consent to the Processing of Facial Images and Voice Recordings (https://promoos.tech/en/face-voice-consent), obtained through the Service interface upon the first use of the relevant features.
3.4.3. Facial images and voice recordings are not used by the Company to establish the User’s identity, for authentication, or for any other purposes unrelated to the generation of the requested Content.
3.4.4. Uploaded facial images and voice recordings, as well as the AI avatars and voice models created on their basis, are stored in the User’s Account so that they can be reused — until they are deleted by the User, until consent is withdrawn, or until the Account is deleted.
3.4.5. Such data are not transferred to third parties, except for AI providers that carry out the technical generation of Content. The transfer is made to the minimum extent necessary to fulfil the User’s request and on terms of confidentiality.
3.4.6. The User may at any time withdraw consent to the processing of facial images and voice recordings through the Account settings or by sending a notice to support@promoos.tech. Withdrawal of consent results in the termination of the use of the relevant features of the Service.
3.5. Data of Partner Program participants
When registering in the Partner Program, the participant provides: type (individual, individual entrepreneur, legal entity), full name of the contact person, telephone number, country of tax residence and, in order to receive payouts, the name or full name of the recipient, TIN, bank account number and bank details. These data are processed for the performance of the Partner Program Rules (https://promoos.tech/en/partner-rules), the calculation and payment of remuneration, and the fulfilment of the Company’s tax obligations.
The Company processes personal data solely for the following purposes:
4.1. Providing access to the Service — identifying the User, maintaining the Account, and enabling the Content generation features.
4.2. Processing payments — interacting with payment partners to charge and confirm payment.
4.3. Generating Content — transmitting input data (prompts, uploaded files) to AI providers. Content cannot be generated without processing the input data.
4.4. Improving the Service — analysing anonymised data on the use of the Service.
4.5. Security and prevention of violations — monitoring activity to detect prohibited use and to protect against unauthorised access.
4.6. Publishing Content to Connected Accounts on the User’s instructions.
4.7. Marketing and communication — sending marketing messages only where a separate Consent to Receive Marketing Communications has been given.
4.8. Performance of the Partner Program Rules — recording referred customers, and calculating and paying remuneration.
4.9. Fulfilment of legal obligations — storing data in accordance with the requirements of applicable law.
5.1. The data subject’s separate consent to the processing of personal data (https://promoos.tech/en/consent).
5.2. Performance of a contract (the Public Offer, the Partner Program Rules) to which the personal data subject is a party.
5.3. Compliance with the Company’s legal obligations.
5.4. The Company’s legitimate interests (ensuring security, preventing fraud) — to the extent permitted by applicable law.
6.1. Account data (email, name, password hash, settings) are stored for the entire period of the Account’s existence.
6.2. The User’s Content is stored for the entire term of the Account. After the Account is deleted, the Content shall be deleted within 30 (thirty) calendar days.
6.3. Technical logs (IP addresses, request dates) are stored for 12 (twelve) months from the date of the User’s last action.
6.4. Facial images and voice recordings are stored for the periods set out in clause 3.4.4.
6.5. The publishing profile identifier is stored until the User disconnects the Connected Accounts or until the Account is deleted.
6.6. Data of Partner Program participants are stored for the period of participation and, after its end, for the period established by tax and accounting legislation for payout documents.
6.7. Exceptions:
7.1. Categories of recipients
7.1.1. AI providers and technical operators — the Company uses third-party providers of AI models and cloud services to generate Content. The current list is published on the Site at https://promoos.tech/en/subprocessors.
7.1.2. Payment partners (Lava.top and others indicated on the Site).
7.1.3. The Yandex Metrica web analytics service (LLC «Yandex», Russian Federation) — for collecting visit statistics. For details, see Section 15.
7.1.4. Telegram Messenger Inc. — acceptance of payments in Telegram Stars.
7.1.5. Ayrshare (Neverminds Solution LLC, USA) and the social networks to which the User has connected an account — Content and publication data are transferred to them on the User’s instructions. Further processing by the platform takes place in accordance with its own rules.
7.1.6. The Partner through whose referral link or promo code the User registered — name, email address, registration date and information on whether payment has been made. The Partner may use these data solely to remind the User about the Service and shall cease contacting the User at the User’s request.
7.1.7. Government authorities — on the basis of a lawful request, in the manner provided for by applicable law.
7.2. Cross-border data transfer
To generate Content, the Company transfers the User’s input data (prompts, uploaded files) to AI providers whose servers may be located outside the Russian Federation and the Kyrgyz Republic, including in the USA, the People’s Republic of China, Singapore and countries of the European Union. The list of providers and countries is available at https://promoos.tech/en/subprocessors. Cross-border transfer of personal data of citizens of the Russian Federation is carried out after notification of the authorised body for the protection of the rights of personal data subjects in the manner established by Article 12 of Federal Law No. 152-FZ, to the extent necessary to fulfil the User’s request.
7.3. Localisation of personal data of citizens of the Russian Federation
7.3.1. In accordance with Part 5 of Article 18 of Federal Law of the Russian Federation No. 152-FZ of 27 July 2006 “On Personal Data”, when collecting personal data of citizens of the Russian Federation, the Company ensures that their recording, systematisation, accumulation, storage, clarification (updating, modification) and retrieval are carried out using databases located in the territory of the Russian Federation.
7.3.2. For this purpose, the Company uses server equipment located in the territory of the Russian Federation to store the following categories of data of Russian Users:
8.1. The User has the right:
8.1.1. to access the personal data being processed and to obtain information about their processing;
8.1.2. to have incomplete, outdated, inaccurate or unlawfully obtained data clarified, blocked or destroyed;
8.1.3. to have personal data deleted (subject to the limitations set out in clause 6.7);
8.1.4. to withdraw consent to the processing of personal data;
8.1.5. to appeal against the Company’s actions to the authorised personal data protection authority of the User’s country (in the Kyrgyz Republic — the State Agency for Personal Data Protection; in the Russian Federation — Roskomnadzor) or to a court.
8.2. Users from the European Union additionally have the right to request restriction of processing and data portability, and to object to processing based on legitimate interests.
9.1. Requests shall be sent by email to: support@promoos.tech.
9.2. A request must contain the email address linked to the Account and a description of the action requested.
9.3. The Company considers a request within the periods established by applicable law, but no later than 10 (ten) business days from the date of its receipt.
10.1. The Company takes the following measures to protect personal data:
10.2. The person responsible for organising the processing of personal data is Taisiia Babarykina, support@promoos.tech.
Upon detecting an unlawful transfer (leak) of personal data, the Company notifies the authorised body and the affected Users within the periods established by applicable law.
12.1. The Company may amend this Policy.
12.2. Amendments take effect 14 (fourteen) calendar days after publication on the Site.
12.3. If the amendments expand the purposes of processing or the categories of personal data, the Company requests new consent from the User.
13.1. This Policy is governed by the law of the Kyrgyz Republic, including the Law of the Kyrgyz Republic No. 58 of 14 April 2008 “On Personal Information”.
13.2. With respect to personal data of citizens of the Russian Federation, the Company complies with the requirements of Federal Law No. 152-FZ “On Personal Data”, and with respect to users from the EU — with the requirements of the GDPR.
OsOO «Promoos» («PromoOS» LLC)
Registration number: 329936-3301-ООО
TIN (INN): 00906202610151
OKPO: 34999498
Registered address: 64b Erkindik Avenue, Pervomaisky District, Bishkek, Kyrgyz Republic
Email: support@promoos.tech
Site: https://promoos.tech
Service: https://account.promoos.tech
15.1. The Site and the Service use cookies and similar technologies (“cookies”) to ensure their operation, analyse usage and improve the user experience.
15.2. Types of cookies used:
15.2.1. Technical (strictly necessary) cookies — ensure the basic functionality of the Site and the Service (authentication, security, saving session settings).
15.2.2. Analytical cookies — used to collect visit statistics by means of Yandex Metrica. They are used only after the User’s consent in the cookie banner.
15.2.3. Marketing cookies — not used.
15.3. On the first visit to the Site, the User is shown a cookie banner offering to accept or reject analytical cookies. The User may change the settings at any time through the Site interface or the browser settings. Rejecting analytical cookies does not affect the ability to use the Service.
15.4. Technical cookies are stored until the end of the session or for up to 30 days. Analytical cookies are stored for the periods established by the Yandex Metrica policy.