Privacy Policy
1. General provisions
1.1. This Privacy Policy (the “Policy”) applies to all information that the team of developers and moderators (the “Company”) of the “Treniki” website at https://trenikivareniki.ru (the “Website”), or the “Treniki” mobile application (the “App”), or other mobile applications, services and websites where this Policy is posted (the “Services”), may obtain about an individual (the “User”) while they visit and/or use them.
1.2. Use of the Service means the User’s unconditional acceptance of this Policy and the terms of processing of their personal information set out herein. If the User disagrees with these terms, they must refrain from using the Service.
1.3. This Privacy Policy applies only to the Service. The Company does not control and is not responsible for third-party websites that the User may access via links available on the Service.
2. Personal information of Users that the Company obtains and processes
2.1. For the purposes of this Policy, the User’s personal information means:
2.1.1. Personal information that the User provides about themselves when registering (creating an account) or while using the Service, including the User’s personal data:
• Email address
• First name, patronymic and last name
• Mobile phone number
• Country and city of residence
• Information about claims, complaints and other inquiries.
2.1.2. Usage data that is automatically transmitted to the Company by the Service’s software while it is used via software installed on the User’s device, including cookie information and information about the User’s device:
• the User’s computer Internet Protocol address (for example, IP address)
• browser type and browser version
• Website / App pages, the User’s visit time, and time spent on those pages
• unique device identifiers and other diagnostic data, mobile device type, mobile device IP address, mobile operating system, mobile Internet browser type, cookie file data.
The Company uses cookie files and similar technologies to track the User’s activity in the Service and to store information. Cookies are small data files that may include an anonymous unique identifier. Cookies are sent to the browser from the website and stored on the User’s device.
Tracking technologies that are also used include beacons, tags and scripts to collect and track information and to improve the Service.
The User may refuse all cookies. By refusing cookies, the User agrees that some parts (features) of the Service may be unavailable.
The Company uses Yandex.Metrica and AppMetrica to collect information about use of the Service, including, in particular, how often users visit the Service, pages visited, and websites from which users arrived at the Service, as well as analytics. The Company uses information obtained via Yandex.Metrica and AppMetrica only to improve the Service. How the owners of those analytics services may use and share with third parties information collected by their systems about the User’s visits to the Service and other data is limited by the privacy policies of those parties. The User may prevent those services from recognizing them on repeat visits by disabling cookies in their browser or by other available means.
2.1.3. Other information about the User the processing of which is provided for by the User’s consent to personal data processing and/or an agreement with the User.
3. Main rights of Users
3.1. With respect to the processing of their personal information, the User has the right to:
3.1.1. receive information relating to the processing of their personal information in the manner provided by Federal Law No. 152-FZ “On Personal Data” (for sending requests to the Company, see Section 8 of this Policy);
3.1.2. take measures provided by law to protect their rights, including requiring the Company to clarify, block or destroy their personal information if it is incomplete, outdated, inaccurate, unreliable or unlawfully obtained;
3.1.3. refuse processing of personal information for direct contacts (including for promoting goods, works or services) if the User’s personal information is processed for such purposes;
3.1.4. withdraw their consent to the processing of personal data by the Company. If the User withdraws consent, the Company may continue processing personal data if other legal grounds for processing exist;
3.1.5. appeal the Company’s actions or omissions to the authorized body for the protection of personal data subjects’ rights (Roskomnadzor) or in court.
4. Purposes of collection and processing of Users’ personal information
4.1. The Company collects and stores only personal information that is necessary to provide the Service or to perform agreements and contracts with the User, or that is processed with the User’s consent to personal data processing, except where the law requires mandatory retention of personal information for a statutory period.
4.2. The Company processes the User’s personal information, including collection, receipt, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (provision, access), blocking, deletion and destruction, with or without automation tools, as well as by mixed processing, for the following purposes:
• concluding and performing user agreements / contracts entered into online with the User
• providing and ensuring the User’s access to the Service and its functionality
• running marketing promotions, if marketing promotions are conducted in the Service
• conducting marketing and other research, and forming personalized offers
• conducting surveys, analyzing user data, and statistical, marketing and other research of the User’s interaction with the Company and third parties; processing the information obtained, including commercial use of the results of such surveys and research; providing personalized offers, additional features and services and information about them; improving the user experience, service quality and operation of the Service
The Company may also process personal information for other purposes that may be provided for by the consent to personal data processing and/or an agreement with the User.
5. Terms of processing Users’ personal information and its transfer to third parties
5.1. Processing of Users’ personal information is carried out in accordance with the Company’s internal regulations on personal data processing, this Privacy Policy, and personal data legislation. The Company has defined a full list of personal data processing purposes, categories of data subjects and data categories, retention periods and processing methods, and the procedure for destruction. Upon the User’s request, the Company will provide the relevant information for review in accordance with Section 8 of this Policy.
5.2. The Company processes the User’s personal information for the purposes stated in clause 4.2 of this Policy in the following cases:
• processing is carried out with the User’s consent
• processing is necessary to exercise the Company’s or third parties’ rights and legitimate interests, provided the User’s rights and legitimate interests are not violated
• processing is necessary to conclude, perform, amend or terminate a contract to which the User is a party or beneficiary
• processing is necessary to perform functions, powers and duties imposed on the Company by Russian law.
5.3. The confidentiality of the User’s personal information is maintained, except where the User voluntarily discloses information about themselves to an unrestricted circle of persons (for example, reviews). The Company does not otherwise further distribute such information.
5.4. The Company may transfer the User’s personal information to third parties and instruct them to process personal information in the following cases:
5.4.1. the User has consented to such actions;
5.4.2. transfer is necessary for the User to use the Service or to perform an agreement with the User;
5.4.3. to enable protection of the Company’s rights and legitimate interests;
5.4.4. in other cases established by law.
5.5. Instructing a third party to process personal information may be based on a relevant agreement with the third party that establishes that party’s duties to maintain confidentiality and ensure the security of personal information.
5.6. The Service may contain links to other websites that are not operated by the Company. If the User follows a link, they will be taken to a third-party website. The Company strongly recommends that the User review the privacy policy of every website they visit. The Company does not control and assumes no responsibility for the content, privacy policies or practices of third-party websites or services.
5.7. The Company stops processing personal information and destroys the User’s personal information upon achieving the processing purposes within no more than 30 calendar days from the date the processing purpose is achieved, unless otherwise provided by law or an agreement with the User.
5.8. If the User requests that processing of their personal information be stopped, the Company stops such processing within 10 business days of receiving the request, if processing is based on the User’s consent. This period may be extended by no more than 5 business days if the Company notifies the User of the reasons for the extension.
6. Measures applied to protect the User’s personal information
6.1. When processing personal information, the Company takes necessary legal, organizational and technical measures to protect personal information from unlawful or accidental access, destruction, alteration, blocking, copying, provision or distribution, and from other unlawful actions regarding the User’s personal information, including:
• developing internal documents on personal data processing, as well as local acts establishing procedures aimed at preventing and detecting violations of Russian Federation law and eliminating the consequences of such violations;
• protecting personal data from unauthorized access, unlawful processing or transfer, and from loss, distortion or destruction;
• defining and implementing, before introducing new personal data processing processes and new personal data information systems, technical and organizational measures that ensure personal data protection;
• identifying threats to the security of personal data when processed in information systems;
• establishing access rules for personal data processed in information systems, and ensuring registration and accounting of actions performed with personal data in information systems;
• monitoring and assessing the effectiveness of applied measures;
• detecting unauthorized access to personal data and other incidents, and taking measures to eliminate and mitigate consequences;
• providing access to personal data only in cases and in the manner provided by Russian Federation law;
• familiarizing employees who directly process personal data with the provisions of Russian Federation law, including personal data protection requirements, documents defining the personal data processing policy, local acts on personal data processing, requirements for non-automated processing, and/or training such employees.
7. Obligations of the Company and the User
7.1. The User shall:
7.1.1. provide the Company with accurate personal information necessary to use the Service;
7.1.2. notify the Company of changes to their personal information within no more than 3 business days from the date of the change.
7.2. The Company shall:
7.2.1. use the personal information obtained solely for the purposes stated in this Privacy Policy, the agreement with the User, and the consent to personal data processing;
7.2.2. maintain the confidentiality of the User’s personal information;
7.2.3. perform other duties provided by the Company’s personal data processing policy.
8. User and authorized body requests and inquiries
8.1. The Company responds to requests/inquiries from Users or their legal representatives, or to requests from state supervisory authorities regarding the processing of personal information, in the manner and within the time periods established by the Company’s local acts and applicable law.
8.1.1. If the Company receives a User’s request about the existence of the User’s personal information or another request under personal data legislation, the Company undertakes to respond to such request and to give the User an opportunity to review their personal information within 10 business days of receiving the request. This period may be extended by no more than 5 business days if the Company notifies the User of the reasons for the extension.
8.1.2. If the Company receives an inquiry from the User or an authorized body concerning unlawful processing of personal information or processing of inaccurate personal information, the Company undertakes to block the relevant personal information from the moment of receiving such request for the period of verification.
8.1.3. If inaccuracy of personal information is confirmed, the Company undertakes to clarify the relevant personal information within 7 business days and lift the blocking of the personal information.
8.1.4. If unlawful processing of personal information is confirmed, the Company undertakes, within no more than 3 business days, to stop the unlawful processing (destroy the relevant information or ensure lawful processing) and, if the unlawful processing was identified in connection with an inquiry from the User or an authorized body, to notify the relevant User or authorized body of the measures taken.
8.2. A User’s or authorized body’s inquiry/request may be sent by email to senatoz@gmail.com.
8.3. A User’s inquiry/request for access to personal information must contain:
• the number of the main identity document of the User or their representative;
• information about the date of issue of that document and the issuing authority;
• information confirming the User’s relationship with the Company, or other information confirming that the Company processes the personal information;
• the signature of the User or their representative.
8.4. The User may contact the Company again or send a repeat request to obtain information relating to the processing of their personal information, and to review the personal information being processed, earlier than 30 days after the initial inquiry or request only if such information or the personal information being processed was not provided to them in full as a result of considering the initial inquiry. A repeat request, along with the required details, must include a justification for sending the repeat request.
8.5. The Company may refuse to fulfill a repeat request that does not meet the conditions described above.
9. Account deletion
9.1. The User may delete their account in the Service at any time. Account deletion terminates the User’s access to the Service. A deleted account cannot be restored.
9.2. How to delete an account in the “Treniki” mobile app:
1) open the “Treniki” app and sign in;
2) go to Profile;
3) tap Delete profile;
4) confirm deletion in the dialog.
9.3. Alternative method: email an account deletion request to senatoz@gmail.com, stating the phone number and/or email address used for registration and requesting account deletion. The Company reviews such requests within the time periods in Section 8 of this Policy.
9.4. Upon account deletion, the following are deleted:
• access to the account (sign-in to the Service with the deleted account becomes impossible);
• the phone number and email address linked to the account (released and may be used for a new registration);
• authorization sessions, access tokens and device push tokens;
• active and pending coach–client links associated with this account;
• pending notifications associated with this account.
9.5. After account deletion, the following may be retained:
• profile details and user-generated content linked to the deactivated account (including name and other profile fields, programs and workouts, exercises, set history, body measurements, avatar) — without the ability to sign in or use them in the Service;
• information that applicable law of the Russian Federation requires to be retained — for the periods established by such law;
• anonymized and aggregated analytics data that does not allow the User to be identified;
• support inquiries and related information — for the period in clause 9.6;
• minimal technical records needed for Service security, fraud prevention and protection of the Company’s rights and legitimate interests (without using deleted contact details to contact the User).
9.6. Retention periods:
• personal information of an active account — for the period of use of the Service and until the processing purposes in Section 4 are achieved;
• after account deletion, access stops immediately; data subject to destruction upon achievement of processing purposes is destroyed within no more than 30 calendar days, unless otherwise required by law (clause 5.7);
• if processing based on consent is to be stopped — within the time periods in clause 5.8 (10 business days, extendable by no more than 5 business days);
• support inquiries — up to 12 months from closure, unless a longer period is required by law or to protect the Company’s rights;
• cookies and analytics — until cookie / device settings expire or per the analytics services’ policies (Yandex.Metrica, AppMetrica);
• data required by law — for the statutory retention period.
10. Additional terms
10.1. The Company may amend this Privacy Policy without notifying the User.
10.2. A new version of the Privacy Policy takes effect when it is posted at https://trenikivareniki.ru/privacy/en, unless otherwise provided by the new version of the Privacy Policy.
10.3. If the User has any questions about this Privacy Policy, they may send a request by email to senatoz@gmail.com.
Internet posting address: https://trenikivareniki.ru/privacy/en
Russian version: https://trenikivareniki.ru/privacy
Publication date: October 6, 2026