Legal document

Privacy Policy

Last updated: 25.05.2026

Last updated: 25 May 2026
Effective date: 25 May 2026

This Privacy Policy explains how personal data is collected, used, stored, shared, and protected in connection with Olga Ugrymova's Culinary Club, including the English Service Website, the main Russian-language Service Website, Telegram-based access tools, Telegram bots, Telegram Mini App, USPAS web platform access, paid creator channels, payment flows, subscription management, customer support, and related digital services.

By using the website, selecting a plan, making a payment, using Stripe, PayPal, Robokassa, Telegram, Telegram Mini App, USPAS, or any official access interface connected with Olga Ugrymova's Culinary Club, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

For international payment flows and related customer access management, the data controller is:

SERGEI KONOVALOV, trading as S.K.
Legal form: Entrepreneur individuel / Micro-entreprise
SIREN: 989 827 043
SIRET: 989 827 043 00013
APE / Main activity code: 62.01Z — Programmation informatique
VAT status: Franchise en base de TVA
Business address: 8 Rue des Platanes, 67810 Holtzheim, France
Business email: sergeinfrance@gmail.com
Company / seller profile website: https://sergeikonovalov.com/

Content Author:
Olga Ugrymova
Author and creator of the culinary content, recipes, educational materials, club publications, and related digital materials.

Service Websites and Access Platforms:
English Service Website: https://club.ugrymova.ru/en
Main Russian-language Service Website: https://club.ugrymova.ru/
International Payments Information Page: https://club.ugrymova.ru/en/international-payments
USPAS platform: a web-based platform where paid creator channels and digital access may be provided.

Official Telegram bot for payment and access:
@ugrymova_kk_bot

Official Telegram support bot:
@ugrymova_support_bot

For Russian domestic payment flows, where a separate Russian seller is clearly displayed, personal data may also be processed by or on behalf of Individual Entrepreneur Konovalova Olga Leonidovna under the applicable Russian-language terms and privacy documents.

2. Related Legal Pages

This Privacy Policy should be read together with the following legal pages:

Terms and Conditions:
https://club.ugrymova.ru/en/terms

Subscription Terms:
https://club.ugrymova.ru/en/subscription-terms

Refund Policy:
https://club.ugrymova.ru/en/refund-policy

Legal Notice:
https://club.ugrymova.ru/en/legal-notice

International Payments Information:
https://club.ugrymova.ru/en/international-payments

3. Scope of This Privacy Policy

This Privacy Policy applies to personal data processed when you:

  • visit the English Service Website;
  • visit the main Russian-language Service Website;
  • read information about Olga Ugrymova's Culinary Club;
  • select a plan or paid access option;
  • make a payment through Stripe, PayPal, Robokassa, or another available payment provider;
  • use a Telegram bot connected with the Service;
  • use a Telegram Mini App connected with the Service;
  • join or request access to a private Telegram channel or community;
  • create or use a USPAS account;
  • access paid creator channels or digital content through USPAS;
  • contact support;
  • request access help, cancellation, refund, or subscription information;
  • interact with official service pages, forms, payment flows, or access systems.

This Privacy Policy applies to both Telegram-based access and USPAS web-based access, depending on the product and access method selected by the customer.

4. Personal Data We May Collect

Depending on how you use the Service, we may collect the following categories of personal data.

4.1. Identity and contact data

We may collect:

  • name;
  • email address;
  • Telegram username;
  • Telegram user ID;
  • Telegram first name and/or profile name;
  • USPAS account email;
  • customer account identifier;
  • billing contact information;
  • support contact information.

4.2. Payment and transaction data

We may collect and store payment-related information such as:

  • payment provider used;
  • payment date and time;
  • payment amount;
  • currency;
  • selected plan;
  • selected product or channel;
  • payment status;
  • order number;
  • invoice or receipt reference;
  • Stripe payment ID or checkout session ID;
  • PayPal transaction ID, where applicable;
  • Robokassa payment ID, where applicable;
  • refund status;
  • subscription status;
  • renewal status;
  • cancellation status;
  • payment provider metadata needed for support, accounting, access management, fraud prevention, and legal compliance.

We do not store full bank card numbers, CVC codes, or full payment card details. Card data is processed directly by the payment provider, such as Stripe, PayPal, Robokassa, or another available payment provider.

4.3. Access and subscription data

We may collect and process:

  • selected subscription plan;
  • access start date;
  • access end date;
  • renewal date;
  • subscription status;
  • cancellation date;
  • grace period status;
  • Telegram channel access status;
  • USPAS paid channel access status;
  • access entitlement records;
  • invite link usage;
  • account activation status;
  • access logs;
  • payment confirmation status.

4.4. Technical data

We may collect technical data such as:

  • IP address;
  • browser type;
  • device type;
  • operating system;
  • language settings;
  • approximate country or region;
  • date and time of access;
  • pages viewed;
  • referral source;
  • error logs;
  • payment flow logs;
  • authentication logs;
  • security logs;
  • cookie and analytics identifiers, where applicable.

4.5. Support communication data

When you contact support, we may collect:

  • your message;
  • email address;
  • Telegram username;
  • USPAS account email;
  • payment details needed to find your order;
  • screenshots or files you send;
  • support history;
  • internal notes needed to resolve your request.

Please do not send sensitive medical, financial, identity, or other unnecessary personal data unless it is strictly required to resolve your support request.

5. How We Collect Personal Data

We may collect personal data directly from you when you:

  • enter your email;
  • create or use an account;
  • make a payment;
  • contact support;
  • use Telegram bot or Telegram Mini App;
  • use USPAS;
  • select a paid channel or plan;
  • request access, cancellation, or refund;
  • interact with the website or official access interfaces.

We may also receive limited data from third-party service providers, including:

  • Stripe;
  • PayPal;
  • Robokassa;
  • Telegram;
  • USPAS platform infrastructure;
  • website hosting and application infrastructure providers;
  • email and support tools;
  • analytics tools;
  • authentication providers;
  • database and storage providers.

6. Purposes of Processing

We process personal data for the following purposes:

  • to provide information about Olga Ugrymova's Culinary Club;
  • to process payments;
  • to confirm successful payments;
  • to provide access to paid digital content;
  • to provide access through Telegram and/or USPAS;
  • to manage subscriptions, renewals, cancellations, and access periods;
  • to send receipts, access instructions, service notifications, and support responses;
  • to prevent fraud, abuse, unauthorized access, and payment disputes;
  • to provide customer support;
  • to verify payment and access issues;
  • to comply with legal, tax, accounting, and regulatory obligations;
  • to maintain security and service reliability;
  • to improve the website, payment flow, and access experience;
  • to keep internal records of orders, payments, access, and support requests.

7. Legal Bases for Processing

If the General Data Protection Regulation (GDPR) or similar data protection laws apply, we process personal data on the following legal bases:

7.1. Contract performance

We process data when it is necessary to provide the Service, process payment, activate access, manage subscriptions, provide Telegram or USPAS access, and respond to customer requests.

7.2. Legal obligations

We process data when necessary for accounting, tax records, consumer protection, legal compliance, fraud prevention, payment dispute handling, and regulatory obligations.

7.3. Legitimate interests

We may process data for legitimate business interests, including service security, fraud prevention, payment verification, technical troubleshooting, customer support, platform reliability, and improvement of the Service.

7.4. Consent

Where required by law, we may ask for your consent for cookies, analytics, marketing communications, or optional data processing. You may withdraw consent where applicable.

8. Payments and Payment Providers

International card payments may be processed through Stripe. Other available payment providers may include PayPal, Robokassa, or another provider displayed before payment.

When you pay through a payment provider, your payment data is processed by that provider according to its own privacy policy and terms.

We may receive limited payment information from the provider, such as payment status, amount, currency, transaction ID, customer email, payment method type, and metadata needed to activate access, manage support, prevent fraud, and comply with legal obligations.

We do not receive or store your full card number or CVC code.

9. Telegram Access

If access is provided through Telegram, we may process Telegram-related data, including:

  • Telegram username;
  • Telegram user ID;
  • Telegram profile name;
  • Telegram bot interaction history;
  • access status;
  • invite link status;
  • channel membership status;
  • messages sent to support bots or access bots;
  • technical events related to access activation or removal.

Telegram is a third-party platform. Your use of Telegram is also subject to Telegram's own terms and privacy policy.

If you block the bot, delete your Telegram account, change Telegram settings, or cannot access Telegram due to technical or regional restrictions, access delivery may be affected.

10. USPAS Access

If access is provided through USPAS, we may process USPAS-related data, including:

  • account email;
  • user ID;
  • creator or channel access status;
  • paid channel membership;
  • payment history;
  • access entitlement;
  • subscription status;
  • login and authentication events;
  • content access events;
  • support and troubleshooting information.

USPAS is used as a web-based platform for paid creator channels and digital access management. Access through USPAS is limited to the products, channels, plans, and access periods purchased by the customer.

11. Website, Hosting, and Technical Infrastructure

The Service may use website hosting, application hosting, database, authentication, storage, and no-code or low-code development infrastructure, including tools such as Lovable, Supabase, and related service providers, where applicable.

These providers may process technical and account data needed to operate the website, payment flow, access system, authentication, database, storage, logs, and service functionality.

We use such providers to host the website, operate the platform, store service data, authenticate users, manage access, process technical events, and provide digital content access.

12. Cookies and Analytics

The website may use cookies or similar technologies to:

  • keep the website functional;
  • improve security;
  • remember preferences;
  • measure website traffic;
  • analyze user behavior;
  • improve the payment and access flow;
  • detect technical errors.

Where required by law, non-essential cookies or analytics tools may be used only with your consent.

You can control cookies through your browser settings. Disabling cookies may affect website functionality, login, payment flow, or access management.

13. Email and Service Notifications

We may send service-related messages, including:

  • payment confirmation;
  • access instructions;
  • subscription status notifications;
  • renewal or cancellation information;
  • support replies;
  • important service updates;
  • legal or policy updates;
  • security notifications.

These messages are necessary for the operation of the Service and are not considered marketing communications.

If marketing emails are used in the future, they will be sent only where legally permitted and with an unsubscribe option where required.

14. Sharing of Personal Data

We may share personal data only where necessary and lawful, including with:

  • payment providers, such as Stripe, PayPal, Robokassa, or another provider displayed before payment;
  • Telegram, where Telegram access is used;
  • USPAS platform infrastructure, where USPAS access is used;
  • hosting and application infrastructure providers;
  • database, authentication, and storage providers;
  • email and support service providers;
  • analytics and technical monitoring providers;
  • accounting, tax, legal, and compliance advisors;
  • public authorities, regulators, courts, or law enforcement where legally required;
  • service providers needed to operate, secure, and improve the Service.

We do not sell your personal data to advertisers.

15. International Transfers

Personal data may be processed in countries outside your country of residence, including countries outside the European Economic Area, depending on the service providers used, payment provider infrastructure, Telegram, hosting services, analytics tools, and platform infrastructure.

Where required by applicable law, we rely on appropriate safeguards for international transfers, such as adequacy decisions, standard contractual clauses, contractual protections, or other lawful transfer mechanisms.

16. Data Retention

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy.

Typical retention periods may include:

  • payment, accounting, and tax records: for the period required by applicable law;
  • order and subscription records: for as long as necessary to manage access, support, disputes, accounting, and legal compliance;
  • Telegram and USPAS access records: for as long as needed to provide and verify access;
  • support messages: for as long as needed to resolve requests, prevent repeated issues, and maintain service history;
  • technical logs: for a limited period needed for security, troubleshooting, and fraud prevention;
  • legal dispute records: for as long as necessary to establish, exercise, or defend legal claims.

When data is no longer needed, it will be deleted, anonymized, or archived where legally required.

17. Data Security

We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

These measures may include:

  • secure payment processing through third-party payment providers;
  • access controls;
  • authentication;
  • database security;
  • secure infrastructure providers;
  • restricted access to administrative tools;
  • logging and monitoring;
  • backup and recovery measures where applicable.

No system is completely secure. Customers are responsible for keeping their own email, Telegram, USPAS, payment provider, and device accounts secure.

18. Your Rights

Depending on your country and applicable law, you may have the right to:

  • access your personal data;
  • request correction of inaccurate data;
  • request deletion of your data;
  • request restriction of processing;
  • object to certain processing;
  • withdraw consent where processing is based on consent;
  • request data portability;
  • lodge a complaint with a data protection authority.

To exercise your rights, contact:

sergeinfrance@gmail.com

or artsimpo@mail.ru

We may need to verify your identity before responding to your request.

Some data may need to be retained for legal, accounting, tax, fraud prevention, dispute resolution, or contract performance reasons.

19. Children's Privacy

The Service is intended for adults aged 18 or older.

We do not knowingly sell access directly to children under 18. If we become aware that personal data of a child has been collected without appropriate legal basis or parental authorization where required, we will take reasonable steps to delete it.

20. Customer Responsibilities

The Customer is responsible for:

  • providing accurate email, Telegram, USPAS, and payment information;
  • keeping account access secure;
  • not sharing access with third parties;
  • notifying support if access details are incorrect;
  • protecting their own device, browser, email, Telegram account, and USPAS account;
  • not sending unnecessary sensitive personal data through support channels.

21. Sensitive Data

The Service does not require customers to provide sensitive personal data, such as detailed medical records, health diagnosis, religious beliefs, political opinions, biometric data, or full identity documents.

Because the content may include nutrition-related and lifestyle information, customers may choose to mention health-related circumstances in support messages. Please avoid sending sensitive health information unless it is strictly necessary for your support request.

The Service materials are informational and educational only and do not constitute medical advice, diagnosis, treatment, or individual nutrition consultation.

22. Automated Decision-Making

We do not use automated decision-making that produces legal or similarly significant effects on customers.

Some automated technical processing may be used to:

  • confirm payment status;
  • activate access;
  • update subscription status;
  • prevent fraud;
  • detect payment errors;
  • manage access through Telegram or USPAS.

These automated processes are necessary for service operation and do not replace customer support where a technical issue needs manual review.

23. Refunds, Disputes, and Fraud Prevention

We may process payment, order, access, and support data to handle:

  • refund requests;
  • cancellation requests;
  • chargebacks;
  • payment disputes;
  • failed payments;
  • duplicate payments;
  • fraudulent activity;
  • unauthorized access;
  • abuse of the Service;
  • violation of Terms and Conditions.

This processing is necessary for contract performance, legal compliance, fraud prevention, and legitimate business interests.

24. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

The updated version will be published on this page with a new "Last updated" date.

If changes are significant, we may provide additional notice through the website, Telegram, USPAS, email, or another official communication channel where appropriate.

Continued use of the Service after publication of the updated Privacy Policy means that you acknowledge the updated version.

25. Contact Details

Seller / Merchant of Record for international payments:
SERGEI KONOVALOV, trading as S.K.
Legal form: Entrepreneur individuel / Micro-entreprise
SIREN: 989 827 043
SIRET: 989 827 043 00013
APE / Main activity code: 62.01Z — Programmation informatique
VAT status: Franchise en base de TVA
Business address: 8 Rue des Platanes, 67810 Holtzheim, France
Business email: sergeinfrance@gmail.com
Company / seller profile website: https://sergeikonovalov.com/

English Service Website:
https://club.ugrymova.ru/en

Main Russian-language Service Website:
https://club.ugrymova.ru/

International Payments Information:
https://club.ugrymova.ru/en/international-payments

Content Author:
Olga Ugrymova
Main website: https://ugrymova.ru/
Culinary Club website: https://club.ugrymova.ru/

Telegram access and support:
Telegram bot for payment and access: @ugrymova_kk_bot
Telegram support bot: @ugrymova_support_bot
General support email: artsimpo@mail.ru

USPAS platform access:
USPAS platform: https://uspas.ru
Olga Ugrymova creator page on USPAS: https://uspas.ru/creators/olga-ugrymova

If access is provided through USPAS, the customer may need to create or use a USPAS account in order to access the paid creator channel, payment history, subscription status, and digital content connected with the purchased product.

Russian domestic seller for Russian payment flows, where displayed separately:
Individual Entrepreneur Konovalova Olga Leonidovna
INN: 526103774902
OGRNIP: 315526200003140
Website: https://club.ugrymova.ru/
Russian public offer page: https://club.ugrymova.ru/oferta/