Privacy Policy

This is an English translation provided for convenience. In case of any discrepancy, the Russian version at https://niva.company/privacy prevails.

1. General Provisions

1.1. This Policy sets out the procedure for processing Users’ personal data in accordance with Federal Law No. 152-FZ “On Personal Data”.

1.2. The terms “Service”, “Contractor”, “User”, “Nika” and “Account” are used in the meanings established by the User Agreement, and the terms “Tariff”, “Limit”, “Free Plan”, “NiVa credits”, “Balance” and “Nika in Chat” are used in the meanings established by the Public Offer.

1.3. The operator of personal data is the Contractor. Address for inquiries regarding personal data: privacy@niva.company.

1.4. The Policy applies to data obtained through the niva.company website and the profile on it, the Telegram bot @NiVaAibot and correspondence with Nika (@Nika_NivaAi) in direct messages and in group chats.

2. Data Processed

2.1. Telegram data: ID, username (@username), name and language – when the bot or Nika is contacted; the referral source (for example, the website or an invitation link) and information about the inviting user; after consent is confirmed in the bot – information from the public Telegram profile: profile bio, date of birth (if public), personal channel, main profile picture (recognized by a neural network model) – for Nika’s first message and for age verification.

2.2. Account data: first name, last name (if provided) and date of birth – for addressing the User and for age verification; sign-in methods – Telegram, email address (if added), Google account identifier and the email address from it (if Google sign-in is added); dates of registration, of Telegram linking and of the last sign-in. When signing in via Google, a link to the Google profile picture (avatar) is saved – for display in the website header. The picture is loaded by the User’s browser from Google’s servers and is shown only to the User.

2.3. Website sign-in information: time and method of sign-in, country determined by IP address, IP address hash and browser string hash. Used to show the User their open sessions and to protect the Account.

2.4. Correspondence with Nika: messages, photos and other images, videos, video messages, GIFs, voice messages, stickers, reactions and links (the content of links to videos is recognized) that the User sends to Nika, and Nika’s responses – in direct messages and in group chats where Nika operates.

2.5. Nika’s memory: diary entries and dated facts that Nika extracts from the correspondence – about the User and about persons the User tells her about.

2.6. Payment data: Tariff, amounts, dates, payment method, transaction ID, Balance transactions (crediting and debiting of NiVa credits), indicators that payment for responses with NiVa credits is enabled and that continuation of correspondence for NiVa credits after the Limit is exhausted is enabled; data necessary for a refund, if the User provides them in a refund request.

2.7. Nika in Chat data: group ID and name, invitation link, selected model.

2.8. Inquiries: messages to support from the profile and from the bot; requests submitted via the “Contact us” form (name, contact, subject, text, IP address); reviews.

2.9. Photos and files (PDF, TXT) may be attached to a support inquiry from the profile. Files are forwarded to support in Telegram and are not stored on the website; only information about the file is saved in the Service database: type, name and size.

2.10. Technical data: IP address – for request rate limiting and the “I’m not a robot” check; log of actions in the profile and in the bot (sign-ins, payments, model changes, promo codes) associated with the Account; marks of the days on which the bot was used; the date on which the User confirmed in the bot that the User is 18 or older, and consent to the Policy and the User Agreement; a mark of suspension of explicit topics where there is information indicating an age under 18; information about service messages of the bot in correspondence with Nika (date of the consent request, message about lack of access, number of deleted messages).

2.11. Team applications: first name, last name, phone number, email address, country and city, Telegram name or a link to another social network, desired role, information about oneself, answers about schedule and readiness to work, consent marks, and, for an agreement with a team member, also patronymic (if provided) and residential address. These were completed after signing in to the account in the candidate application form; acceptance of applications is closed, and applications received earlier are stored for the periods set out in Section 6. When an approved candidate signs the agreement, the following are saved: the text of the signed version with the candidate’s data, the checked confirmation items, the time of signing, the method and time of sign-in to the profile, the IP address and browser information.

2.12. NiVa Security Guard protection system log: sender ID, chat, number and time of the message in which an attempt to obtain Nika’s service information or to circumvent her rules was detected, the text of such message, the type of attempt and the number of warnings, including with respect to participants of Nika in Chat group chats.

3. Purposes and Legal Grounds for Processing

3.1. Data are processed for the following purposes:

age verification, including automated analysis of correspondence and of the date of birth in the Telegram profile for signs of an age under 18;
generating Nika’s responses and maintaining her memory – the main function of the Service;
enabling access, accounting for the Limit and NiVa credits, accepting payments and recording transactions;
considering support inquiries and complaints;
considering applications of candidates to the team and communicating with them;
protecting the Service and Accounts from unauthorized access, fraud and violations of rules;
sending service messages: sign-in codes, sign-in notifications, payment confirmations, support responses;
improving the Service based on usage statistics in aggregated form.

3.2. Legal grounds for processing: performance of contracts (the User Agreement and the Public Offer), the User’s consent and legal requirements, including requirements on accounting.

4. Correspondence with Nika

4.1. Messages to Nika are processed automatically by neural network models. To generate a response, to recognize images and videos and to operate the protection system, the correspondence, including images, videos and transcripts of voice messages, is transferred via the OpenRouter service to providers of neural network models, including outside the Russian Federation. Requests are sent only to those model providers that, according to OpenRouter, do not collect request data, including for model training. Data storage on the side of OpenRouter and of the model providers is governed by their rules.

4.2. When searching the internet, the search query is transferred to a search service.

4.3. Correspondence and Nika’s memory are stored so that Nika remembers her conversation partner and the content of past conversations.

4.4. Correspondence and Nika’s memory are processed automatically: so that Nika can respond and in order to improve the quality of responses. The Contractor opens the User’s correspondence only in the following cases: upon the User’s support inquiry or upon a complaint – to the extent necessary for the response; messages in which the NiVa Security Guard protection system detected an attempt to obtain Nika’s service information or to circumvent her rules (clause 4.8) are stored together with their text in the protection system log and are available to the Service administrators for review without a request from the User.

4.5. Nika may save any information provided by the User, including information about health and about third parties. The User should not tell Nika any information that the User is not prepared to share with the Service. Such entries are deleted upon request in the manner set out in Section 7.

4.6. In a group chat (Nika in Chat), Nika reads the participants’ messages, responds to messages addressed to her and may save what is said in the chat. A participant who objects to the processing may ask the buyer to remove Nika from the chat or may send a request to privacy@niva.company; information about the participant saved by Nika is deleted. If the protection system (clause 4.8) detects in a participant’s message an attempt to obtain Nika’s service information or to circumvent her rules, the buyer receives a warning with the name and username (@username) of that participant. After Nika leaves the chat, the information she saved about the chat is stored for the periods set out in Section 6.

4.7. The Contractor does not sell personal data and does not use correspondence for advertising.

4.8. Messages to Nika, including text in images and videos, are automatically checked by the NiVa Security Guard protection system before being processed by Nika. A message in which an attempt to obtain Nika’s service information or to circumvent her rules is detected is not processed by Nika and, in direct messages, is deleted from the correspondence. After the first warning, the User’s subsequent messages are also analyzed by a neural network model. The text of messages in which such an attempt is detected is saved in the protection system log (clause 2.12) for recording warnings, for review by the Service administrators (clause 4.4) and for consideration of inquiries.

5. Transfer of Data to Third Parties

5.1. Data are transferred to the following persons to the extent necessary for the operation of the Service:

Telegram – correspondence with Nika and the bot, service notifications, including service messages of the bot in correspondence with Nika; requests from the website and support inquiries with attached files are forwarded to administrators in Telegram; team applications are forwarded to the owner of the Service in Telegram;
Cloudflare – hosting of the website and the delivery network through which requests to the Service pass, sending of emails, the “I’m not a robot” check (Cloudflare Turnstile receives the IP address and technical information about the browser); Cloudflare servers are located, among other places, outside the Russian Federation;
OpenRouter and the providers of neural network models to which OpenRouter sends requests – for generating Nika’s responses, recognizing images and videos and operating the protection system (Section 4); the servers are located, among other places, outside the Russian Federation;
the buyer of Nika in Chat – the name and username (@username) of a group chat participant in a protection system warning (clause 4.6);
a search service – when searching the internet;
Google – when signing in via Google, as well as when the website fonts are loaded: Google receives the IP address and browser information;
banks – to the extent necessary for payment;
government authorities – only upon a lawful request.

5.2. Transfer of data outside the Russian Federation is necessary for the operation of the Service. By accepting this Policy, the User consents to the cross-border transfer of personal data for the purposes specified in Section 3.

6. Retention Periods

Account, correspondence, Nika’s memory, support inquiries, Balance and transaction history – for the period of use of the Service or until a deletion request is received;
payment data – for the period established by accounting legislation;
requests from the website, the action log and the protection system log – for the period of use of the Service or until a deletion request is received;
team applications – 12 months from the last change to the application or until a deletion request; applications and signatures of team members – for the entire term of the non-disclosure agreement (the period of cooperation and three years thereafter);
request rate counters – up to two days;
a website sign-in session is valid for no more than 60 days and ends after 14 days of inactivity; records of ended sessions are deleted within 7 days;
sign-in codes and links are valid from 3 to 10 minutes and are stored only as a hash;
log of sent emails – 30 days; addresses to which emails cannot be delivered are stored so that emails are not sent to them again;
service records of model requests containing correspondence text – up to 48 hours, for troubleshooting.

7. User Rights

7.1. The User may obtain information about the User’s personal data, demand its correction, withdraw consent to processing and demand deletion of the Account, the correspondence and Nika’s memory.

7.2. A request is sent to support – in the profile (the “Поддержка” (Support) section) or in the bot @NiVaAibot – or to privacy@niva.company. Response time – up to 10 business days. The Account is deleted upon such a request.

7.3. In the bot @NiVaAibot, in the “Что Ника помнит” (What Nika remembers) section, the User can delete individual entries of Nika’s memory or tap “Стереть всё” (Erase everything). “Erase everything” deletes everything Nika stores about the User: diary entries about conversations with the User, facts about the User, the User’s card, short-term memory, promises and tasks related to the User. This does not delete the correspondence in Telegram itself. If the User asks Nika in the correspondence not to use a certain fact, Nika stops relying on it, but the entry is not deleted.

7.4. When the Account is deleted upon a request under clause 7.2, the Account, the correspondence and Nika’s memory are deleted. Payment records are anonymized: the amount, date and tariff remain for accounting purposes, and the link to the User is removed. A ban on using the Service imposed for violation of the Terms remains in effect.

7.5. If the User’s rights are violated, the User may apply to Roskomnadzor.

8. Data Protection

8.1. Connections to the Service are encrypted (HTTPS). Sign-in codes and session tokens are stored only as hashes.

8.2. Sign-in via Telegram is confirmed in the bot. Upon a sign-in to the website by email, via Google or with a button in the bot, the bot sends a message with the “Это не я – закрыть этот вход” (It wasn’t me – close this sign-in) button; all sessions can be ended in the profile (the “Настройки” (Settings) section, “Сессии” (Sessions)).

8.3. The sign-in page and the “Contact us” form are protected by the “I’m not a robot” check (Cloudflare Turnstile), and requests to the website are protected by rate limiting.

8.4. Only administrators have access to administrative data; their actions are logged. The Contractor collects the minimum amount of data necessary for the operation of the Service.

9.1. The website uses only strictly necessary cookies:

__Host-niva_sid – profile session, up to 60 days; not accessible to page scripts;
niva_in – a sign-in indicator used to show the profile in the website header; contains no secret data;
__Host-niva_oauth – for 10 minutes, only during sign-in via Google.

9.2. Advertising and analytics cookies are not used, and no cross-site tracking is performed.

10. Age

The Service is intended for persons who have reached the age of 18. An Account with a date of birth according to which the User is under 18 is not registered, and the Telegram account linked to such Account does not obtain access to correspondence with Nika. If the correspondence, Nika’s memory or the date of birth in the Telegram profile indicates that the User may be under 18, explicit topics in the correspondence are suspended until the User confirms their age in the bot with the “Мне есть 18” (I am 18) button in the manner set out in clause 4.4 of the User Agreement.

11. Changes to the Policy

A new version of the Policy is published on this page with its date. The Contractor notifies Users of material changes in the bot or by email.

12. Contacts

Personal data matters – privacy@niva.company. Support – in the profile (the “Поддержка” (Support) section) and in the bot @NiVaAibot (the “Поддержка” (Support) button).