Documents

Privacy Policy

Version dated October 10, 2026. Effective upon first publication.

This English version is a translation of the Russian version of this document. In the event of any discrepancy between the English and Russian versions, the Russian version shall prevail.

1 General Provisions

1.1. This Policy describes what data Desow LLC (Limited Liability Company «Дезау») (the "Company") processes when the desow.ru and online.desow.ru websites and the Desow service are used, for what purposes, and how the User can exercise their rights.

1.2. The personal data operator (the "Operator") is Desow LLC, PSRN 1254000006556, TIN 4000027225. Address: Russian Federation, Kaluga Region, Kaluga, Kirova St. 20, office 404. For inquiries: support@desow.ru.

1.3. The Policy applies to the data of website visitors, registered Users, and other persons whose information is contained in User materials. Personal data means information relating to an identified or identifiable individual.

1.4. The Policy provides information about processing and is not consent to it. The necessary consents are obtained separately before the relevant processing begins. Rights to materials are determined by the Terms; the existence of a license does not replace the legal basis for processing personal data.

2 What Data We Process and Why

2.1. Depending on the functions used, we process data for the following purposes. If material contains the data of another person, a legal basis is required with respect to that person; the consent of the account holder does not replace it.

Account and access: name or alias, email, phone number if provided, authorization details and the authority of a representative.

Legal basis: Entering into and performing a contract; separate consent where necessary.

Retention period: Until the account is deleted; certain information is retained further only under clause 6.4.

Tasks and projects: source files, requests, masks, results, settings, ratings, and history.

Legal basis: Performing the task and storage; for the data of other people, an independent lawful basis.

Retention period: Under clause 6.1; training data is retained separately under clause 6.3.

Purchases and payments: information about payments, subscriptions, transactions, and balance; the payer's details for documents.

Legal basis: Performance of the contract; accounting and tax obligations.

Retention period: Until the purchase and settlements are completed; documents - the mandatory periods under clause 6.4.

Feed, profile, and links: selected works, name, avatar, description, likes, and subscriptions to the extent disclosed.

Legal basis: Performance of the selected function; separate consent to dissemination where necessary.

Retention period: Until the publication is removed, access is revoked, the account is deleted, or the basis ceases.

Security and diagnostics: IP address, device, browser, time, actions, error logs, and necessary cookies.

Legal basis: Performance of the contract and legitimate security interests without infringing a person's rights.

Retention period: Until the diagnostics or review is completed; necessary cookies - until the function is completed; a dispute - under clause 6.4.

Support: contacts, the request, and attachments.

Legal basis: Performance of the contract, legal obligations, and protection of rights in respect of the specific request.

Retention period: Under clause 6.4.

Training: materials, requests, results, settings, and ratings.

Legal basis: License under the Terms; for personal data, the separate consent of the relevant person.

Retention period: Until the purpose, license, or consent ends, under clause 6.3.

Analytics: technical information, actions, and analytics cookies.

Legal basis: Separate consent where necessary; otherwise an appropriate lawful basis.

Retention period: Until the analytics purpose is achieved or the basis ceases; thereafter - under clause 6.5.

Advertising and mailings: published results, agreed public information, and contacts for mailings.

Legal basis: License under the Terms and the necessary separate consents.

Retention period: Until the permission or consent ends; deletion - under clauses 4.6 and 6.2.

2.2. The data of visitors, Users and their representatives, persons in materials, and applicants is processed. Automated and non-automated methods are used: collection, recording, systematization, storage, clarification, retrieval, use, transfer to the necessary extent, depersonalization, blocking, and destruction.

2.3. The contractual basis applies only to the necessary performance toward the relevant data subject. It does not automatically extend to training, advertising, and the data of third parties. Additional purposes and the necessary consents are governed by sections 3, 4, and 8.

3 Uploads and Model Training

3.1. Source files, requests, results, settings, and quality ratings under any plan, including non-public projects, may be used to train, fine-tune, and validate Desow models. Publication in the Feed is not required; the limits of the license and the right to opt out are set out in clauses 6.17-6.19 of the Terms.

3.2. Materials are used only where sufficient rights exist. To train on personal data, the Company obtains the separate consent of the relevant person or a verified representative; the User's consent does not cover other people. Without confirmed grounds, materials are not included in training.

3.3. Before uploading, you should hide unnecessary faces, documents, addresses, bank details, and other personal information. If they are needed for the task, the User must have a basis for transferring and processing them and must provide the necessary confirmations. The Company excludes processing for purposes for which no basis exists.

3.4. Opting out of training or withdrawing consent does not prevent the use of the core functions. Deleting a material, a project, or an account stops further training on the relevant materials under clause 6.18 of the Terms. When the basis for processing personal data ceases, the Company stops processing and destroys the data within the mandatory periods set by law, unless there is an independent basis for another purpose.

3.5. Materials may be transformed and depersonalized for training. Deleting the account name does not, by itself, depersonalize an image. Non-public materials are not disclosed for training or advertising without a separate lawful basis.

4 Public Feed and Advertising

4.1. At the User's chosen action, the result, description, tags, tool, and settings are posted in the Feed, linked to the public profile. The source file is not published together with the result. Access by link is governed by clause 6.4 of the Terms; the existence of a link does not remove the requirements for personal data.

4.2. Before public posting, the contents of the profile and social information are shown. Login and payment data are not disclosed. For the dissemination of personal data, separate consent is obtained, specifying the list of data, the conditions, and the option to set the prohibitions provided for by law; these conditions are taken into account when publishing and using references.

4.3. Advertising use of results published in the Feed is governed by clauses 6.5-6.7 of the Terms. Source files, non-public generations, and works available only through the "share" function are not used for advertising.

4.4. Name, avatar, profile link, and other personal data are used in advertising only on an independent lawful basis, including the necessary separate consent covering the advertising purpose and dissemination. Images of real people also require permission in the cases provided for by law.

4.5. The term of the advertising permission and its termination are determined by clauses 6.5-6.7 of the Terms. A separate notice is not sent for each placement; a person's right to stop the dissemination of their personal data is preserved.

4.6. Removing a publication ends its display in the Feed and any further advertising use; deleting an account deletes its public profile and publications. The deadlines for removing advertising are set out in clause 6.6 of the Terms. When the basis for disseminating personal data ceases, the mandatory procedure and deadlines set by law apply, regardless of the term of the advertising license.

5 Data Transfers and Protection

5.1. For the relevant functions, providers of AI and computing infrastructure, hosting, payments, email, and analytics, as well as technical contractors, are engaged. Only the volume necessary for the purpose is transferred, on a lawful basis. Payments are processed, in particular, through Robokassa. Information about recipients and processing is provided to the data subject upon a lawful request.

5.2. Processing on behalf of the Company is formalized by an agreement covering purposes, data, actions, confidentiality, protection, and termination of processing. Recipients that perform generation do not receive independent permission from the Company to train their own models; use of materials for other purposes is permitted only on a separate appropriate basis.

5.3. Personal data of citizens of the Russian Federation is collected in compliance with the requirement to localize databases in Russia. Subsequent cross-border transfer is permitted only after the requirements of Article 12 of Federal Law No. 152-FZ "On Personal Data" are met, including the necessary prior notification of Roskomnadzor. Transfer to government authorities is permitted on a lawful basis.

5.4. The Company restricts access and applies the organizational and technical security measures provided for by law, including with respect to engaged contractors.

6 Retention and Deletion

6.1. Desow is not intended for guaranteed long-term archival storage; the User keeps the necessary copies. Account data is retained for access until the account is deleted; materials are retained for the task and the available history until deletion or until storage ends. A planned end of storage is announced in advance, with an opportunity to save copies; urgent deletion is possible upon a lawful demand or in the event of a violation. This does not cancel paid obligations or the right to settlement under the Offer.

6.2. Public information is posted until the publication is removed, the account is deleted, or the basis for dissemination ceases. Advertising materials are deleted under clause 6.6 of the Terms, with priority given to the mandatory periods for personal data.

6.3. Training datasets are retained until the need, the license, or the basis for processing ceases. The maximum term of the license is 3 years under clause 6.17 of the Terms; personal data is additionally limited by the term and purpose of the consent. Upon opt-out or deletion of materials, further training stops under clause 6.18 of the Terms. Materials without personal data are removed from active datasets without undue delay; personal data - within the mandatory periods set by law.

6.4. Payment documents are retained for the mandatory accounting and tax periods. Requests and logs are retained until the review, diagnostics, or security check is completed; evidence in a specific dispute - until it is resolved and the applicable limitation period for claims expires. These grounds do not permit training or advertising.

6.5. After the basis ceases, data is destroyed within the periods set by Article 21 of Federal Law No. 152-FZ, unless there is another lawful basis for retention. Data in backup copies is subject to the same requirements; if timely destruction is not possible, it is blocked and destroyed within the maximum period established by law. Deleting an account does not destroy documents subject to mandatory retention.

6.6. Removal from a dataset does not automatically cancel the influence of the material on a trained model. If the model makes it possible to obtain the personal data of a specific person, the requirements of the law also apply to such processing.

7 Rights and Requests

7.1. A person has the right to obtain information about the processing of their data, to demand its clarification, blocking, or destruction in the cases provided for by law, to withdraw consent, and to appeal the company's actions to Roskomnadzor or a court.

7.2. To submit a request, write to support@desow.ru, stating your demand and the details needed to find the account or material. Where necessary, the Company requests information to verify identity or authority. A request for information is considered within 10 business days, with a possible extension permitted by law of no more than 5 business days upon a reasoned notice. For clarification, termination of processing, blocking, and destruction, the periods for the relevant demand under Federal Law No. 152-FZ apply; the general period for a moderation appeal does not apply to them.

7.3. Withdrawal of consent does not end processing on an independent lawful basis, for example, the mandatory recording of payments. If a specific function cannot be performed without the data being deleted, that function is terminated; the consequences for a paid purchase are determined by the Offer. Opting out of training does not disable the core functions.

8 Cookies and Changes to the Policy

8.1. Necessary cookies are used for authorization and settings. Yandex.Metrica may be used for analytics; where consent is required, analytics is enabled after separate consent, which can be withdrawn. Opting out of analytics does not, by itself, disable the core functions; blocking necessary cookies may limit them.

8.2. Advertising messages are sent with the necessary consent; opting out is available in the message and via support@desow.ru. Service notifications about performance, payments, price changes, and security are sent for the operation of the Service.

8.3. New versions are published on desow.ru with an effective date. They do not expand consents; new necessary consents are obtained before processing. Individual notices are sent when required by law.