Dilbat Pro Personal Data Processing Policy
Version of October 11, 2026. Document address: masters.dilbat.app/en/privacy.
1. General provisions
1.1. The policy describes how the individual entrepreneur Khludeyev Artem Sergeevich, Republic of Kazakhstan, Almaty (the "Operator"), processes the personal data of users of the Dilbat Pro plan and their clients.
1.2. Contact for personal data matters: support@dilbat.app.
1.3. By paying for the plan and ticking the consent on the payment page, the user agrees to this policy.
2. Whose data we process
| Who | The Operator's role |
|---|---|
| The practitioner — a Dilbat Pro user | Operator |
| The practitioner's clients — people who write to their bot, use their calculator, buy their course | Processing on the practitioner's instruction. For them the operator is the practitioner |
3. What practitioner data we process and why
| Data | Purpose | Retention period |
|---|---|---|
| Name, email, phone, Telegram | Registration, communication, access to the plan | Subscription term + 3 years |
| Photo, logo, social media handle, field of practice | Calculator, PDF reports, bot and course under the practitioner's name | Subscription term + 30 days |
| The practitioner's Telegram bot token | Operation of the practitioner's bot | Subscription term. Deleted when switched off |
| Telegram ID and Telegram username, WhatsApp number, club membership status | Opening and closing access to the Dilbat Pro club (Telegram channel and chat, WhatsApp community) | Subscription term + 30 days |
| Payment data (amount, date, last 4 digits of the card, payment identifier) | Payment records, auto-renewal, refunds | 5 years under accounting requirements |
| Technical data: IP, device, in-app events | Security, statistics, improving the service | 1 year |
We do not receive or store full bank card data: it is processed by the payment agent.
4. What data of the practitioner's clients passes through the service
| Data | Where | Why |
|---|---|---|
| Telegram id, Telegram name, source of the visit, time of steps | The practitioner's bot | Delivering the gift, the message chain, statistics for the practitioner |
| Date of birth | Calculator and bot | Calculation. Not stored in the bot. In the calculator it is stored only if the client themselves saved the calculation in their own account |
| Email, name | Registration in Dilbat via the practitioner's link | Account and crediting the affiliate percentage to the practitioner |
Dates of birth, names and licence keys are not passed to analytics systems.
5. Legal grounds
- The agreement with the practitioner (the Dilbat Pro offer).
- The consent of the personal data subject.
- The practitioner's instruction to process the data of their clients.
- Compliance with legal requirements (payment records).
6. Instruction to process the data of the practitioner's clients
6.1. By accepting the offer, the practitioner instructs the Operator to process the data of their clients within the scope of section 4 and only for the operation of the practitioner's bot, calculator and course.
6.2. The practitioner undertakes to obtain the consent of their clients to such processing. The Operator embeds a template of the consent text in the bot and on the practitioner's course page.
6.3. The Operator:
- processes clients' data only on the practitioner's instruction;
- does not use it for its own advertising;
- observes confidentiality and the protection measures from section 8;
- deletes the practitioner's clients' data within 30 days after the subscription ends, if the practitioner has not renewed it.
7. Where data is stored and to whom it is transferred
7.1. The servers of the service and of the processors listed below are located outside the Republic of Kazakhstan.
7.2. We transfer data only to those needed for the operation of the service:
| Recipient | What it receives | Why |
|---|---|---|
| Payment agents (JSC "T-Bank", Plexy) | Payment data, email | Accepting payment, auto-renewal |
| Telegram | Bot messages | Operation of the bot |
| Telegram | The club member's Telegram ID | Access to the club channel and chat |
| WhatsApp (Meta Platforms) | The club member's phone number | Access to the club community for English-speaking practitioners |
| Google (Google Drive) | Nothing except the fact that the folder was opened by link | Storage of course materials |
| Email service Resend | Email, text of the message | Sending emails |
| Google Analytics 4 | Anonymised events | Statistics |
| Hosting Railway | All data of the service | Hosting of the service |
7.3. Data is processed abroad: the servers of the recipients in the table are located outside the Republic of Kazakhstan. By paying for the plan and ticking the consent on the payment page, you agree to such transfer.
8. How we protect data
- Access to the database is only for employees who need it for their work.
- Connection encryption (HTTPS).
- Keys, tokens and secrets are stored outside the code.
- Full keys and payment data are not stored in logs.
9. User rights
You can:
- find out what data of yours we process;
- correct it;
- demand its deletion;
- withdraw consent.
Write to support@dilbat.app. We will reply within 10 business days. Withdrawal of consent may make it impossible for the plan to keep working.
10. Changes to the policy
A new version is published on this page with a date. We inform you of material changes by email.