PRIVACY POLICY

and personal data processing

Version dated 1 November 2026

This is an informational English translation. The Russian version published at https://swagat.ru/privacy is the legally binding edition.

This Policy describes how the operator processes personal data of users of the website https://swagat.ru (the "Website") and of the personalised comic creation services.

Data operator: sole proprietor (self-employed) Mirotvortsev Vasily Aleksandrovich, INN 772828179026 (the "Operator").

Contact for personal data matters: mirotvorcevvasily@gmail.com.

1. General Provisions

1.1. This Policy is developed in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data".

1.2. This Policy applies to all personal data received by the Operator through the Website and in connection with the provision of services.

1.3. By using the Website and placing an order, the user confirms that they have read this Policy and agree to the processing of data to the extent necessary to provide the service.

1.4. The service is not intended for persons under 18 years of age. By placing an order, the user confirms that they are 18 or older.

2. Data We Process

2.1. Data provided by the user:

• email address;
• character name (optional) and character details;
• story description and personal details (optional);
• photographs uploaded to create the comic, including images of faces;
• promo code (if used).

2.2. Order data: theme, volume, language, order status, creation date, price.

2.3. Payment data: amount, date, status, payment identifier. The Operator does not receive or store full bank card details — they are processed by the YooKassa payment provider.

2.4. Technical data: IP address, browser and device information, date and time of access, requested page address, referral source, interface language, session identifier. This data is used to operate the Website, determine language and country, prevent abuse and analyse service performance.

2.5. The Operator does not collect data about health, religion, political views or other special categories of data. Users are prohibited from uploading such information in photographs or descriptions.

3. Purposes of Processing

3.1. Creating the comic based on uploaded photographs and story information.

3.2. Providing access to the preview, the finished comic and the PDF file.

3.3. Sending service messages: sign-in links, order status notifications, comic readiness notifications.

3.4. Sending informational and marketing messages (reminders, offers) — only with consent; the user may unsubscribe at any time via the link in the email.

3.5. Handling requests, refunds and claims.

3.6. Ensuring Website security and preventing abuse and fraud.

3.7. Complying with legal requirements, including tax legislation.

4. Legal Bases

4.1. The user's consent to personal data processing.

4.2. Performance of the agreement to which the user is a party (public offer).

4.3. Performance of obligations imposed on the Operator by law.

4.4. The Operator's legitimate interests in ensuring security and preventing abuse, where this does not violate the user's rights.

5. Transfer of Data to Third Parties

5.1. To provide the service the Operator engages:

• the YooKassa payment provider — for accepting payments;
• image generation and text processing service kie.ai — for creating comic illustrations and text;
• email service and hosting — for delivering emails and operating the Website.

5.2. Third parties receive only the data necessary to perform the relevant function.

5.3. Cross-border transfer. Photographs and text data are transferred to the foreign service kie.ai for image generation and text processing. The transfer is carried out to the extent necessary to provide the service, in accordance with 152-FZ. By placing an order, the user consents to such transfer.

5.4. The Operator does not sell personal data or transfer it for third-party advertising purposes.

6. Retention Periods

6.1. Uploaded photographs are deleted no later than 90 days after the order is completed — after the comic is created they are no longer needed. The finished comic (pages, cover, PDF file) remains in the personal account until the user requests deletion, so it can be revisited at any time. Unfinished unpaid orders (including free previews) are deleted in full after 90 days.

6.2. The user may request early deletion of their photographs and comics by contacting the Operator.

6.3. Payment and order data required for tax and accounting records are stored for the period established by the legislation of the Russian Federation.

6.4. Technical logs are stored no longer than necessary for security and incident investigation.

6.5. Once the purposes of processing are achieved, data is deleted or anonymised.

7. User Rights

7.1. To receive information about the processing of their personal data.

7.2. To request clarification, blocking or deletion of data if it is incomplete, outdated, inaccurate or unlawfully obtained.

7.3. To withdraw consent to personal data processing.

7.4. To opt out of marketing messages without refusing service messages.

7.5. To appeal the Operator's actions to Roskomnadzor or a court.

7.6. Requests are sent to mirotvorcevvasily@gmail.com or comics@swagat.ru and are reviewed within 10 business days.

8. Photographs of Children

8.1. The Website is intended for persons over 18 years of age.

8.2. Photographs of minors may be uploaded only by their legal representatives — parents, guardians or trustees.

8.3. By uploading a photograph of a minor, the user confirms that they are the legal representative and consents to the processing of the image for the purpose of creating the comic.

8.4. If photographs of minors are uploaded without proper authority, the Operator may refuse the service and delete the materials.

9. Cookies and Local Storage

9.1. The Website uses cookies and browser local storage to:

• remember the selected language;
• maintain the personal account session;
• store a session identifier for service analytics;
• prevent abuse.

9.2. The Website does not use advertising trackers and does not transfer data to advertising networks.

9.3. The user may restrict cookies in browser settings, but this may disrupt the operation of the Website.

10. Security Measures

10.1. The Operator takes organisational and technical measures to protect data: access restrictions, encrypted transmission (HTTPS), backups, server access control.

10.2. Only the Operator and the services listed in Section 5 have access to photographs and orders, to the extent necessary to provide the service.

10.3. In the event of a data incident, the Operator takes measures to eliminate the consequences and notifies users where required by law.

11. Changes to the Policy

11.1. The Operator may amend the Policy by publishing a new version on the Website.

11.2. The new version takes effect upon publication unless a different period is stated.

11.3. Continued use of the Website after publication of the new version constitutes acceptance of it.

12. Contacts

Sole proprietor (self-employed) Mirotvortsev Vasily Aleksandrovich

INN: 772828179026

Email: mirotvorcevvasily@gmail.com

Customer support: comics@swagat.ru

Website: https://swagat.ru