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Personal Data Processing Policy

Website ooofferly.com (the “Website”)

This is an English translation provided for convenience. The legally binding version is the Russian one (Политика обработки персональных данных); in case of any discrepancy, the Russian text prevails. Processing is governed by the law of the Russian Federation.

1. General provisions

1.1. This Personal Data Processing Policy (the “Policy”) is drawn up in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and defines how the Operator processes personal data and the measures taken to ensure their security.

1.2. Operator: Alisa Kostolomova, self-employed (professional income tax payer), TIN (INN) 772589042300, Moscow, Russia. Contact for requests: hi@ooofferly.com.

1.3. The Operator processes users' personal data in connection with the use of the Website and the provision of the services described in the Public Offer.

1.4. By using the Website and/or submitting data through its forms, the User consents to the processing of their personal data under this Policy.

2. What data is processed

2.1. The Operator processes the following data:

2.2. The Operator does not request special categories of personal data and asks the User not to include them in uploaded documents.

3. Purposes of processing

4. Legal grounds

4.1. Processing is carried out on the basis of: the User's consent to the processing of personal data; the necessity of performing the contract (the Public Offer) to which the User is a party; the requirements of applicable Russian law.

5. Procedure and conditions of processing

5.1. Personal data is processed using automation.

5.2. The contents of uploaded documents are processed in memory to generate the result of the service. By using the Website and uploading a document, the User agrees that the Operator may retain: (a) the uploaded file itself in its original format (PDF/DOCX/TXT), (b) an ANONYMIZED version of the document's text content AT EACH STAGE of processing, including intermediate outputs of the AI service (the résumé assessment, the suggested target-role and market options, the draft and final result of the document rewrite), as well as choices and actions the User makes along the way (the selected target role/market/goal, accepted or declined improvement suggestions) — with full name and contact details replaced by placeholder values while preserving the overall structure and wording of the text, as well as prior employer/company names stated in the document (retained WITHOUT masking) — for the purpose of quality control, analytics (including which companies are most frequently referenced by the service's users), and improving the AI service, including its further training. The uploaded file is stored without the original filename or other direct identifiers in its storage path; access to stored files is technically restricted (not published or provided on request). The result is provided to the User in its original form to download themselves.

5.3. To provide the service, certain data may be transferred to the Operator's providers solely to the extent necessary to perform the contract:

5.4. Cross-border transfer. When the automated processing provider is used, data may be processed on servers located outside the Russian Federation. By using the Website, the User confirms their consent to such transfer to the extent necessary to provide the service.

5.5. The Operator does not transfer personal data to third parties for purposes other than those specified in this Policy, except as provided by Russian law.

6. Processing and storage periods

6.1. The uploaded file, an anonymized version of its content, and the result of processing (see clause 5.2) may be retained by the Operator indefinitely for the purpose of improving the quality of the service, unless otherwise required by applicable law.

6.2. Contact data is processed until the purposes of processing are achieved or until the User withdraws consent.

7. Cookies and local storage

7.1. The Website may use technical cookies and browser local storage (e.g. to remember the chosen interface language).

7.2. To improve the service and understand how users move through the funnel, the Operator may use web analytics (PostHog, EU hosting) and Vercel Web Analytics. Aggregated usage events are collected: funnel steps, role/market choices, CV score bands (0–100 numbers), payment and download events. CV text, job postings and generated output are never sent to analytics.

7.3. Analytics uses an anonymous session id in sessionStorage and PostHog cookies. To opt out, email hi@ooofferly.com.

8. Rights of the data subject

8.1. The User has the right to: obtain information about the processing of their personal data; request the clarification, blocking or deletion of data if it is incomplete, outdated, inaccurate or processed in breach of the law; withdraw consent to processing.

8.2. To exercise these rights, the User sends a request to: hi@ooofferly.com. The Operator considers the request within the periods established by Russian law.

9. Data protection

9.1. The Operator takes reasonable and sufficient legal, organisational and technical measures to protect personal data against unlawful access, destruction, alteration, blocking, copying and distribution.

10. Changes to the Policy

10.1. The Operator may amend this Policy. The current version is published on the Website at ooofferly.com. Continued use of the Website after changes means acceptance of the updated Policy.

11. Operator's details

Operator: Alisa Kostolomova

Status: self-employed (NPD payer)

TIN (INN): 772589042300

Address: Moscow, Russia

E-mail: hi@ooofferly.com

Website: ooofferly.com