Privacy Policy for Personal Data

This Privacy Policy (hereinafter referred to as the "Policy") applies to all information that the mini app in Telegram (hereinafter referred to as the "mini app"), located in the Telegram bot @wisp_vpn_bot, may receive about the User while using the mini app, its programs, and products.

This Policy was developed in accordance with the requirements of the Federal Law "On Personal Data" No. 152-FZ.

1. Terms and Definitions

This Policy uses terms as defined in Federal Law No. 152-FZ "On Personal Data":

• Bot Administration — Authorized personnel who manage the bot on behalf of the operator, organize and/or carry out the processing of personal data, determine processing purposes, and outline data sets and operations performed.
• Personal Data — Any information related directly or indirectly to an identified or identifiable individual.
• Processing of Personal Data — Any operation or series of operations using automated means or not, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, destruction.
• Confidentiality — The requirement for the operator or other parties with access not to disclose data without user consent or legal justification.
• Mini App — A set of interconnected webpages available online via the Telegram mini app @wisp_vpn_bot.
• User — An individual accessing the WispVPN Telegram bot and mini app via the Internet and using its content and services.
• IP Address — A unique network address used by the User to access WispVPN.
• Product — An item the User purchases via the bot and pays for through payment systems.

2. General Provisions

By using the Telegram bot and mini app, the User agrees to this Privacy Policy and the terms of personal data processing.

If the User disagrees with these terms, they must stop using the Telegram bot and mini app.

The Policy applies only to the mini app. WispVPN does not control or bear responsibility for third-party websites accessed via links in the mini app.

The Administration does not verify the accuracy of personal data provided by the User.

3. Scope of Policy

The Policy establishes the Administration's commitment not to disclose or misuse personal data obtained during registration, newsletter sign-up, or order processing.

Data collected includes:

• Full name
• Telegram ID
• Telegram username
• Profile photo (if needed)

Automatically collected data includes:

• IP address
• Cookies
• Browser data
• Referrer URL

Disabling cookies may limit access to certain features.

WispVPN uses IP data for technical and security purposes. Other information (e.g., visit history, OS, browser type) is securely stored unless otherwise stated.

4. Purposes of Data Collection

User personal data may be used for:

• Identifying and authorizing Users
• Providing personalized access
• User communication (support, notifications)
• Determining location for fraud prevention
• Verifying submitted data
• Creating an account (with consent)
• Email notifications
• Technical support
• Promotions, price info, newsletters (with consent)
• Advertising (with consent)

WispVPN uses Yandex.Metrica for analytics. Data is anonymized and inaccessible to unauthorized persons.

5. Information Sharing

Personal data is not sold, traded, or transferred to third parties, except:

• Trusted service providers (e.g., payment services) bound by confidentiality agreements
• Legal authorities if required by law

Only necessary data is shared.

6. Data Processing Methods and Duration

Personal data is processed indefinitely, via lawful methods, both automated and manual.

Data may be transferred to third parties (couriers, telecom providers) solely for completing orders.

Data may also be shared with Russian government authorities when legally required.

In case of data loss or leakage, the Administration is not obliged to inform the User.

All measures are taken to protect data from unauthorized access or misuse.

The Administration and User collaborate to prevent losses caused by data breaches.

7. Rights and Responsibilities

User Rights:

• Freely decide to provide data and give consent
• Update or supplement personal data
• Request clarification, blocking, or deletion of inaccurate or unlawfully collected data
• Take legal action to protect rights

Administration Duties:

• Use data only for specified purposes
• Maintain confidentiality unless otherwise allowed
• Use standard protective measures
• Block data upon lawful requests or findings of inaccuracies

8. Liability

Administration is liable for damages unless:

• Data was public prior to disclosure
• Data was obtained from a third party
• Disclosure was consented by the User

Users are responsible for complying with Russian laws, including advertising and copyright rules.

Users recognize that third-party content may be protected by intellectual property rights.

Text content may be shared with a link to WispVPN.

Administration is not liable for:

• Lost content or technical failures
• Unauthorized access
• Third-party behavior

Users are liable for any copyrighted material shared without permission.

9. Dispute Resolution

Before filing legal claims, Users must submit informal complaints (written or digital) for voluntary settlement.

Response time is 30 calendar days.

If unresolved, disputes are handled by Arbitration Court under Russian law.

10. Additional Terms

The Administration may update the Policy without User consent.

New versions take effect upon publication unless stated otherwise.

Questions regarding this Policy can be sent to: support@bear-vpn.ru

Current version: https://bearvpn.ru/en/privacy

Updated: July 24, 2025