1. Who we are
This Privacy Policy explains how Individual Entrepreneur Komarov Nikita Sergeevich (the "Seller", "we", "us", or "our") collects, uses, stores, shares, and protects personal data in connection with the website https://komarowfit.online/, the Posture Reset Program, the checkout process, student dashboard access, support, refunds, and related service communications.
Seller: Individual Entrepreneur Komarov Nikita Sergeevich. OGRNIP: 324508100499343. INN: 503468367464. Country of registration: Russian Federation. Contact email: komarowfit@yandex.ru.
Where applicable, the Seller acts as a personal data operator under Russian personal data law and as a data controller under applicable data protection laws, including the GDPR/UK GDPR where those laws apply.

2. Scope
This Privacy Policy applies to personal data processed when you visit the Website, purchase the Program, create or use student dashboard access, contact support, request a refund, submit optional feedback or progress materials, or interact with our service communications.
This Privacy Policy does not cover websites, payment pages, platforms, or services operated by third parties, except where this Policy explains how we use such providers in connection with the Program.

3. Personal data we may collect

We do not require you to provide detailed medical information to purchase the Program. Please do not send sensitive medical information unless it is necessary for your request. If you voluntarily provide health-related information, injury information, progress photos, or similar sensitive content, we will process it only for the limited purpose for which it was provided, such as responding to your request, providing support, handling consent-based testimonials, or complying with legal obligations.

4. How we use personal data

• to process purchases, payments, access instructions, and refunds;
• to provide access to the Program and student dashboard;
• to send password setup instructions, service notices, payment confirmations, account messages, and important Program updates;
• to respond to support, legal, and refund requests;
• to protect the Website, course platform, content, intellectual property, and users from fraud, abuse, unauthorized access, or misuse;
• to maintain tax, accounting, and legal records;
• to improve the Website, Program, user experience, and technical performance;
• to send marketing emails only where allowed by law and where a valid consent or other lawful basis applies;
• to use testimonials, reviews, progress photos, or stories only where you have given separate permission or where another lawful basis applies to that specific use.

5. Legal bases for processing
Where GDPR/UK GDPR applies, we rely on one or more of the following legal bases:

• Contract: to process your purchase, create access, provide the Program, respond to support requests, and handle refunds.
• Legal obligation: to keep accounting, tax, payment, compliance, and legal records.
• Legitimate interests: to protect our business, prevent fraud, secure the Website and course platform, enforce the Terms & Conditions, improve the service, and respond to non-marketing communications.
• Consent: for optional marketing emails, non-essential cookies where required, certain testimonial uses, and any sensitive information voluntarily provided where consent is required by law.

6. Payment processing
Payments are processed by third-party payment processors, banks, card networks, or checkout providers. These providers may collect payment details directly from you. We do not intentionally collect or store full payment card numbers, CVV codes, or complete banking credentials.
Payment processing may involve providers located in different countries, and payments may be processed or settled to the Seller in the Russian Federation. The relevant payment provider may apply its own terms, privacy policy, security rules, and compliance procedures.

7. Service providers and sharing
We may share personal data with service providers only where reasonably necessary for the purposes described in this Policy. Such providers may include:

• payment processors and checkout providers;
• course platforms and student dashboard providers;
• website hosting and technical infrastructure providers;
• email delivery and customer support tools;
• analytics and advertising providers, if enabled and permitted by applicable consent rules;
• professional advisers, accountants, legal advisers, and compliance providers;
• public authorities, courts, regulators, or law enforcement where required by applicable law.

We do not sell your personal data as a standalone product. We do not publish your progress photos, name, review, or personal story for marketing purposes without your separate permission or another lawful basis that applies to the specific use.

8. International transfers
Because the Seller is registered in the Russian Federation and may use international service providers, your personal data may be processed in countries other than your country of residence, including the Russian Federation and countries where our service providers operate.
Where data protection law requires a transfer mechanism or additional safeguards, we rely on appropriate safeguards, lawful transfer mechanisms, contractual arrangements, or applicable derogations, including where transfer is necessary to perform the contract with you or to take steps at your request before entering into a contract.

9. Data retention
We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide Program access, maintain your account, process refunds, resolve disputes, comply with tax and accounting obligations, protect legal rights, and prevent fraud or misuse.
Different categories of data may be stored for different periods. For example, order and payment-related records may be kept for legal, tax, and accounting purposes; support communications may be kept while needed to resolve requests and protect legal rights; optional testimonial materials may be used until the relevant consent is withdrawn or the use is otherwise discontinued where required by law.
When personal data is no longer needed, we will delete, anonymize, or securely restrict it where reasonably possible and legally appropriate.

10. Your rights
Depending on your country of residence and applicable law, you may have rights to:

• request access to personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request deletion of personal data;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent;
• request a copy or transfer of certain data where applicable;
• unsubscribe from marketing emails;
• file a complaint with a competent data protection authority where applicable.

To exercise your rights, contact us at komarowfit@yandex.ru. We may need to verify your identity before responding. Some rights may be limited by legal, tax, accounting, security, anti-fraud, contractual, or legitimate business requirements.

11. Security
We use reasonable legal, organizational, and technical measures designed to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction. However, no website, email system, payment process, or online platform can be guaranteed to be completely secure.
You are responsible for keeping your login details, password, access link, and devices secure.

12. Children
The Program is intended for individuals aged 18 or older. We do not knowingly target or sell the Program directly to children. If the Program is purchased for or used by a person under 18, it may only be used with the consent and supervision of a parent or legal guardian, as stated in the Terms & Conditions.

13. Cookies and similar technologies
The Website may use cookies or similar technologies that are strictly necessary for the Website, checkout, security, or student dashboard to function. If we use non-essential cookies such as analytics, advertising, remarketing, or tracking pixels, we will handle them in accordance with applicable consent requirements and any Cookie Policy or cookie notice made available on the Website.
You can also control cookies through your browser settings. Disabling certain cookies may affect Website, checkout, or dashboard functionality.

14. Marketing communications
We may send transactional and service-related messages without separate marketing consent where necessary to provide the Program, including purchase confirmations, access links, password instructions, account notices, refund responses, and important Program updates.
Marketing emails, if any, will be handled in accordance with applicable law and the consent or unsubscribe options provided to you. You can unsubscribe from marketing emails using the unsubscribe link or by contacting us.

15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The updated version will be posted on the Website with a new “Last updated” date. Material changes may also be communicated by email or through the Website where appropriate.

16. Contact
For privacy, data protection, access, deletion, correction, or other requests, contact: komarowfit@yandex.ru.

Individual Entrepreneur Komarov Nikita Sergeevich | OGRNIP 324508100499343 | INN 503468367464 | https://komarowfit.online/ | komarowfit@yandex.ru