Privacy policy

Personal Data Processing Policy (full text)

Personal Data Processing Policy for users of the "Athar" mobile app

Version of 18 October 2026. In force from its publication on athar.ac.

Translation. The legally binding original is the Russian text. If there is a discrepancy, the Russian text prevails.

Previous version: of 12 October 2026

1. General

1.1. This Policy sets out how personal data of users of the "Athar" mobile app (the "App") is processed and protected under Russian Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (the "Law").

1.2. Operator: Abdelrahman Yahya, an individual; a citizen of the Arab Republic of Egypt residing in the Russian Federation; e-mail for requests: [email protected]. Website: https://athar.ac.

1.3. The App uses the same accounts as the operator's website. This Policy covers data processed through the App. The website's own policy governs processing on the website (as of the date of this version, no separate website policy has been published).

1.4. The App contains no ads, advertising IDs, trackers or analytics tools. The Android App includes Google's Firebase Cloud Messaging SDK, used only to deliver push notifications the User has turned on (section 12); it is not used for advertising or analytics. The operator does not sell personal data and does not give it to third parties for their own purposes.

1.5. Consent-based processing relies on a separate document, the "Consent to the Processing of Personal Data". The user accepts it separately from this Policy and from the Terms of Use (Law, art. 9 part 1).

2. Data subjects

2.1. The App is used only with an account. 2.2. Registered users (the "User"), including: - students whose admission has been verified (where available); - volunteer mentors (where available); - customers of the document translation service (where available); - community moderators and translators to whom the operator has granted that role.

3. Personal data processed

3.1. Without an account, the operator collects no personal data in the App. When the App contacts servers (to sign in, register or check for updates), hosting providers may automatically record technical request data (IP address, time, request type) in their logs. Log retention periods are set by the providers (Supabase, Cloudflare) in accordance with their own rules.

3.2. Account: e-mail address; the name the User enters (display name); interface language; registration date; authentication data (a password hash, or a Google sign-in identifier where that method is available); saved opportunities.

3.3. Settings and personalisation: - general location ("in Russia" or "outside Russia", with no city or address); - interests (scholarships, olympiads, language courses, etc.); - notification settings by type; - an avatar chosen from a ready-made set (photo upload is not supported); - onboarding completion flags; - "notify me at launch" sign-ups for upcoming features; - "interested" / "not for me" reactions to quick opportunities.

3.4. "My journey" (where available): stage (exploring, applying, accepted, preparing to travel, arrived, studying), target study level and fields; tracked opportunities with a status and a personal note (up to 1,000 characters); checklist completion marks, including the preparation checklist on an opportunity's page. Application statuses are the User's own notes, not a confirmation from the organiser.

3.5. Proof of admission (where available): university, city, level, field, academic year; the acceptance-letter file (PDF or image, up to 10 MB); review status and reason for refusal or revocation. The letter may contain other information about the User that the university included.

3.6. Mentoring and private messages (where available): mentor profile (headline, bio, languages, topics, capacity); mentoring requests with a message; the text of private messages between mentor and student; read receipts; mentoring ratings and comments.

3.7. Community (where available): questions and answers (posts); group-chat messages; community membership; any restrictions applied (mute, removal, ban).

3.8. Safety and moderation: reports (reason, optional description up to 1,000 characters, decision); the list of people the User has blocked; account restrictions (term and reason); the log of moderator and administrator actions (see 10.2).

3.9. Notifications: in-app inbox items (a generic title and text — without the content of messages or documents — and read status), including notifications about messages, mentoring, community activity, admission verification and the User's translation orders; device data: platform, app version, language and distribution edition; and, only after the User turns on phone notifications on the device, the device push token issued by Firebase Cloud Messaging (see section 12).

3.10. Translation service (where available): - document type and languages; name in Russian; desired deadline; notes; - uploaded documents: passport, school certificate, diploma, transcript, or medical documents, as the User chooses; - proof of payment (receipts, screenshots), amount, currency, payment method; - order correspondence; correction requests; delivered translations.

3.11. Athar Assistant. (a) Basic mode (available to everyone): the question is matched against Athar's guides and published opportunities on the device; it is not sent to the operator or to any provider and is not stored. (b) Smart Assistant (optional, only if the operator has enabled it and the User turns it on with their own Google Gemini API key): the key is stored only on the User's device, encrypted with Android Keystore, and is never sent to the operator. The question — after e-mail addresses, phone numbers and messenger links are removed automatically — and excerpts from Athar's public guides and published opportunities are sent directly from the device to Google under the User's key, Google's Gemini API terms and Google's privacy policy. The operator does not receive, store or pay for these requests. On Google's free tier, Google may use prompts and responses to improve its products and they may be reviewed by humans, so the User should not enter personal or sensitive information. (c) If the User taps "Report this answer", the chosen reason, the question (with contacts removed) and the answer are sent to the operator (see 3.14).

3.12. Data on the User's device (not sent to the operator): the sign-in session (in encrypted Android Keystore storage), language, theme, search filters, an offline copy of the public opportunities catalogue, guide reading progress, local reminders; the Smart Assistant's Gemini API key, if the User adds one (encrypted with Android Keystore), and the selected model name; the list of opportunities selected for comparison; translation files the User downloads to save or share (in the App's private cache until the next download or sign-out).

3.13. Special categories and biometric data. The operator does not ask about racial or ethnic origin, political views, religious beliefs, health and similar matters. However, a User may choose to upload a medical document or a document with a photo (passport) for translation.

3.14. App feedback, answer reports and error reports: the text of feedback the User sends themselves via "Send feedback about the app" and its type (problem/idea/other), with the app version and platform; reports about Smart Assistant answers the User sends themselves: the reason (wrong information, offensive, potentially harmful, other), the question (after e-mail addresses, links, identifiers and long numbers are removed automatically) and the answer, with the app version and platform; and technical interface error reports: the error type and text after e-mail addresses, links, identifiers and long numbers are removed automatically, the screen name, app version and platform, linked to the account. Purpose: fixing faults, improving the app and reviewing reported AI-generated content. Error reports are shown without the user's identity; with feedback and answer reports the operator sees only the display name.

3.15. Early-access request: status and dates of submission and review.

4. Purposes and legal bases

5. Processing operations and methods

5.1. The operator processes data by automated means, including: - collection, recording, systematisation, accumulation, storage; - clarification (updating, changing), retrieval, use; - transfer (provision, access), within the limits in section 6; - blocking, deletion, destruction.

5.2. The operator makes no decisions with legal effects for the User based solely on automated processing. Automatic checks are not such decisions. Examples: blocking contact details in messages, rate limits, filtering the catalogue by interests.

6. Who can access the data

6.1. Other users see only what the features need: - display name, avatar, and "moderator" / "verified" badges; - for verified students, the university (and in the mentor directory also city, level and field); - the text of posts, and of messages in communities the viewer belongs to; - private messages, which only the two participants can see.

E-mail addresses are never shown to other users. Posts and communities are available only to signed-in users.

6.2. Community moderators (users the operator has given that role) see reports and messages in their communities, the member list, and who is muted.

6.3. The operator and administrators: in the App's administration interface — only after signing in with two-factor authentication; such actions are recorded in the log. - They read private messages only after a report, and only up to 10 messages before and after the reported one. - They can open acceptance letters only after the opening is recorded in the log.

6.4. A translator assigned to an order sees only what the translation needs: the documents, the name in Russian, notes and the deadline, as well as the order correspondence after payment is confirmed. Translators do not see the User's e-mail, prices or payment proof.

6.5. Processors (parties processing data on the operator's behalf):

6.6. Google Gemini API (Smart Assistant) is not engaged by the operator: requests are sent from the User's device under the User's own key and agreement with Google (3.11(b)). The operator does not receive them.

7. Storage location and cross-border transfer

7.1. Account data and all data in section 3 (except 3.12) are stored in the Supabase database and storage on servers in Switzerland (Zurich, AWS region eu-central-2).

7.2. If the User turns on push notifications, the device push token and the notification's generic title are transferred to Google LLC for delivery, including to servers outside the Russian Federation (USA).

7.3. If the User turns on the Smart Assistant, their question (with contacts removed) and public excerpts are sent from the User's device to Google LLC under the User's own agreement with Google, including to servers outside the Russian Federation; the operator does not take part in this transfer (3.11(b), 6.6).

8. Retention periods

8.1. How the periods are applied. Periods marked * are applied by an automatic server process that runs daily; each run is recorded in the audit log. If a run is missed, the next run catches up, so data may be kept up to a few days longer than the stated period. The same daily process deletes acceptance letters (section 8.3) and carries out account deletions (section 9). Other ways data is deleted are stated in the table.

8.2. Features active in the current App version

8.3. Features that depend on server switches or that the User turns on (proof of admission, mentoring and private messages, communities, push notifications, the Smart Assistant): data is processed only while the feature is on for the User; the periods below apply from that moment.

9. Deleting the account and data

9.1. The User can delete the account directly in the App: "Account → Delete account" (also from "Your data & privacy", and from the early-access and consent screens even before the User is admitted). The screen lists what is deleted and what may be kept; if the last sign-in was more than 10 minutes ago, the App asks the User to confirm the password or Google sign-in. A request can also be sent by e-mail from the account's address to [email protected].

9.2. Immediately after the request: - the mentor profile is disabled; - pending requests are cancelled; - active mentorships end; - posts awaiting moderation are withdrawn.

9.3. For 7 days after the request, the User can cancel the deletion in the same section.

9.4. After 7 days, the account and all related data are permanently deleted, including uploaded files (acceptance letters, translation documents). Deletion is completed no later than 30 days from the request (Law, art. 21 part 5). Deletion is carried out by a scheduled server process or by an administrator; either way each request and the date it was carried out are recorded. Until deletion is carried out the account still exists, and the App shows the scheduled date and a cancel button.

9.5. After deletion, only two things remain: - audit-log entries without the link to the name and e-mail, until their section 8 period ends; - backups, until the operator deletes them manually (target: 30 days).

9.6. Community messages sent by the User are deleted with the account. A private conversation with a mentor is deleted in full, including the other person's messages.

10. Security measures

10.1. Technical measures in the App: - row-level security on every App database table; - data written through server functions that check permissions, or to the User's own records protected by row-level security (RLS) policies; - encrypted connections (HTTPS); - the session stored encrypted on the device (Android Keystore); - the Smart Assistant's API key stored only on the device, encrypted with Android Keystore; it is not written to logs and is not sent to the operator; - translation files downloaded for saving or sharing are kept in the App's private cache and deleted at the next download and on sign-out; - private file storage with no public links, and time-limited file links (60 seconds for acceptance letters, 5 minutes for translation documents); - mandatory two-factor authentication for administrators and for sensitive moderator actions (bans); - an automatic filter that blocks phone numbers, e-mails and messenger links in messages; - rate limits.

10.2. The audit log is append-only. It records document openings, verification decisions, moderation actions, role assignments and deletion requests. Only an administrator with two-factor authentication can read it; a moderator can read the entries for their own community.

10.3. Push tokens are not included in data exports and are not written to technical logs.

10.4. Incidents. If personal data is unlawfully disclosed, the operator notifies Roskomnadzor within 24 hours, and of the investigation results within 72 hours (Law, art. 21 part 3.1). The operator also notifies the affected Users.

11. Minors

11.1. Features for interacting with other users (mentoring, private messages, communities, posts) are open only to people who confirm they are 18 or older. This is a self-declaration; age is not checked against documents.

11.2. During Early Access, the App is intended for people aged 18 or older; age is confirmed when the Terms of Use are accepted. The translation service on the website is available to people aged 18 or older (confirmed when placing the order). There is no technical age check at sign-up.

11.3. The Smart Assistant is offered only to Users who confirm they are 18 or older (Google's requirement for the Gemini API). The confirmation is the same self-declaration as in 11.1 and is recorded when the Smart Assistant is turned on. Withdrawing the age confirmation turns the Smart Assistant off and deletes the key from the device.

12. Notifications

12.1. In-app inbox notifications are generated on the server. The User can turn off each notification type in settings; all types are on by default.

12.2. Push notifications use Firebase Cloud Messaging (Google) in the Google Play and RuStore editions; the SDK is part of every Android build but the direct-download edition does not use it. On devices without Google services push is unavailable and notifications appear only in the in-app inbox. Push is used only after the User turns on phone notifications in the App's notification settings and grants Android's notification permission. A push contains only a short generic title and an in-app link — never the content of messages or documents. The User can turn off any notification type in the App, turn off phone notifications on this device in the App's notification settings, or sign out; in the last two cases this device's token is deleted from the operator's server. Revoking Android's notification permission stops delivery. Until push is enabled on the server, notifications appear only in the in-app inbox.

12.3. Deadline reminders are created and stored only on the device, and only if the User turns them on; turning them on asks for notification permission. "Add to my calendar" opens the device's calendar app with a pre-filled event; the App does not read or write the calendar itself and does not ask for calendar permission.

12.4. App permissions. At run time the App asks only for the notification permission (Android 13 and later), when the User turns on reminders or phone notifications. It does not ask for access to the camera, microphone, location, contacts or device storage; documents are chosen through the system file picker and only the chosen file is uploaded.

13. Data-subject rights

13.1. The User has the right (Law, arts. 14–17, 21): - to information about the processing of their data, and a copy of it; - to have data clarified, blocked or destroyed if it is incomplete, outdated, inaccurate or processed unlawfully; - to withdraw consent; - to complain about the operator to Roskomnadzor or a court.

13.2. How to exercise these rights in the App: - Copy of your data: "Your data & privacy → Download my data". This is a JSON file with the account data and what the User wrote. Other people's messages are not included. Document files are downloaded separately on their own screens. - Change name and language: in account settings. - Withdraw consent to the rules and the age confirmation: "Consents & blocked users → Withdraw". - Withdraw consent to personal-data processing as a whole: request account deletion (section 9) or write to the operator. The App has no separate button to withdraw the main consent: withdrawal is made by requesting account deletion, and processing stops once it is carried out. Only the additional statements (community rules, mentor rules, age confirmation) can be withdrawn separately. - Delete: section 9.

13.3. E-mail requests are answered within 10 working days. This can be extended by no more than 5 working days, with notice of the reasons (Law, art. 20). A withdrawal of consent is carried out within 30 days (Law, art. 21 part 5).

14. Changes to this Policy

14.1. The current version and its date are published in the App ("Privacy policy") and at https://athar.ac/en/app/privacy/.

14.2. For material changes, the operator notifies Users in the App and asks for new consent where needed. Material changes include new purposes, new data categories, new recipients, or a change of storage location.

15. Contacts

Personal data, moderation and complaints: [email protected]. We reply within 10 working days.