Consent to the cross-border transfer of personal data
This is a translation for convenience. The binding version of this document is the Russian one, published at the same address without the language prefix. If the English and Russian texts differ in any way, the Russian text prevails.
This Consent to the cross-border transfer of personal data (the «Consent») is given in accordance with Article 12 of Federal Law No. 152-FZ of 27 July 2006 «On Personal Data». By giving the Consent, the user (the «Subject») permits the Operator to carry out cross-border transfer of their personal data on the terms set out below.
1. The Operator
The Operator is the sole proprietor Igor Naumovich Bolshim (OGRNIP 325508100387287, INN 500300383171), email: info@dobro-code.ru.
2. Grounds and purpose
2.1. Certain functions of the «Kontent zavod DobroKod» service are provided by third-party services whose servers are located outside the Russian Federation. Providing those services requires personal data to be transferred to the territory of foreign states.
2.2. The Subject consents to the cross-border transfer of their personal data, including to states that do not provide adequate protection of the rights of data subjects, being aware of the risks involved.
3. Categories of recipients and states of transfer
Transfer is made to the following categories of foreign recipients, to the extent necessary to provide the services:
- providers of text generation technology (including Anthropic, OpenAI, DeepSeek);
- the provider of video and AI-presenter generation (HeyGen);
- the publishing platforms the Subject connects to their projects themselves (including Meta Platforms — Facebook, Instagram; TikTok; Google/YouTube).
The states of transfer are determined by the jurisdictions of those services (including the United States and other states where their infrastructure is located). The list is updated as the set of engaged services changes.
4. The data transferred and the purposes
4.1. Depending on the function used, the following is transferred: the content of requests and material sent for generation (project brief texts, topics, uploaded material), as well as the data needed to publish to the channels the Subject has connected, and the access tokens for them.
4.2. Purposes of transfer: generating and processing content, and publishing material to the channels chosen by the Subject.
5. Risks
The Subject is informed that the states of transfer may lack legal regulation equivalent to the requirements of the legislation of the Russian Federation, and that exercising the subject's rights in respect of data transferred to foreign recipients may be difficult.
6. Term and withdrawal
6.1. The Consent is effective until the purposes of transfer are achieved or until it is withdrawn.
6.2. The Subject may withdraw the Consent by sending a request to info@dobro-code.ru. Withdrawing the Consent may make it impossible to use the functions of the service that require cross-border transfer (generation through foreign providers, publishing to foreign platforms).