Русский · English · Privacy Choices

Timora Privacy Policy

Version of September 26, 2026

1. General provisions

1.1. This Privacy Policy (the “Policy”) sets out the procedure and conditions for processing the personal data of users of the Timora software (the “Service”) and the measures taken to protect such data. The Policy has been prepared in accordance with Federal Law No. 152-FZ “On Personal Data” of July 27, 2006 (the “Personal Data Law”) and pursuant to Article 18.1(2) of that law.

1.2. The personal data operator (controller) is the developer of the Timora software (the “Operator”). Enquiries regarding the processing of personal data are accepted by email at timora-supp@yandex.ru and via Telegram: @y0rence.

1.3. The Policy applies to all personal data that the Operator obtains about a user through the Timora mobile apps for iOS and Android and the Timora mini apps in Telegram and VK.

1.4. The user reads the Policy before starting to use the Service. The user gives consent to the processing of personal data separately in the Service interface — for specific purposes and categories of data, where such consent is required by law (Section 3).

1.5. The current version of the Policy is permanently available at https://mytimora.ru/app/privacy-en.html. In the event of any discrepancy between language versions, the Russian version prevails.

2. Definitions

3. Legal bases for processing

3.1. The Operator processes personal data on the following legal bases (Article 6(1) of the Personal Data Law):

3.2. The user may withdraw consent to the processing of personal data at any time (Section 9 and Privacy Choices).

4. Personal data processed

CategoryPurposeLegal basisRequired
Selected educational institution and study groupShowing the schedule, basic settingsPerformance of an agreementYes
Service settings (theme, tab bar style, reminders, display of breaks and notes)Interface operation, sync across devicesPerformance of an agreementYes
Random device identifier and session tokenTechnical communication with the serverLegitimate interestYes
First and last nameIdentification within the accountConsentOnly when signed in
Email address (if provided)Display in the profile, replies to the user’s enquiriesConsentNo
Telegram user ID and usernameSign-in with Telegram, bot notificationsConsentOnly with Telegram sign-in
VK user ID and nameSign-in with VKConsentOnly with VK sign-in
Apple ID identifier (Sign in with Apple)Sign-in with AppleConsentOnly with Apple sign-in
Profile photo (uploaded by the user or obtained from Telegram/VK)Display in the profileConsentNo
EIOS login and passwordSigning in to EIOS on behalf and at the instruction of the user to obtain grades and certificate requestsConsentOnly for EIOS features
Grades, examination information, certificate requestsShowing academic performance and certificate statusConsentNo
Full name, study group, role (student, group leader, deputy), verification statusAttendance recordsConsentNo
Class attendance marks; class locations specified by the group leaderAttendance recordsConsentNo
Distance to the class location and location accuracyConfirming presence at a classConsentNo
Device coordinates — only at the moment of class check-in or route planning; not storedCheck-in, routesConsentNo
Personal class notes“Class notes” featureConsentNo
Group leader notes for the group“Group leader notes” featureConsentNo
Push token, educational institution and groupDelivering notificationsConsentNo
Text of support enquiries (“Report a problem”)Handling the enquiryPerformance of an agreementNo
Number of Service launches per day linked to the account or device identifierUsage statisticsLegitimate interestYes
Aggregated data on banner impressions and clicks (not linked to the user)Counting ad impressionsLegitimate interestYes, unless ads are turned off
IP address, request time and pathSecurity, abuse preventionLegitimate interestYes

4.2. The Operator does not request or process special categories of personal data (Article 10 of the Personal Data Law). If the user enters such information in a note or enquiry, it is stored encrypted and used only for the operation of the respective feature.

4.3. The Operator does not process biometric personal data (Article 11 of the Personal Data Law).

4.4. The Operator does not sell personal data, does not use it to track users across third-party apps and websites, and does not display advertising personalised on the basis of the user’s personal data.

5. Purposes of processing

5.2. The Operator does not make decisions that produce legal effects concerning the user or otherwise affect the user’s rights and legitimate interests based solely on automated processing of personal data (Article 16 of the Personal Data Law).

6. Procedure and conditions of processing

6.1. Personal data is processed by automated means, to the extent necessary to achieve the purposes of processing (Article 5 of the Personal Data Law).

6.2. Some data is stored on the user’s device: settings, saved schedules, the EIOS password. In the iOS app, the password, tokens and profile are stored in the Keychain; in the Android app, in storage encrypted with an Android Keystore key. This data is not included in device backups.

6.3. On the server, full names, email addresses, EIOS logins and Telegram and VK usernames are stored encrypted (AES-256-GCM). The EIOS password is stored on the server only with the user’s express permission (“EIOS password on server”, off by default), encrypted with a separate key. Encryption keys are stored separately from the database; the password is decrypted automatically and only for requests to EIOS made at the user’s instruction.

6.4. The mini apps use the messenger browser’s local storage (localStorage) for settings and cache. The Service does not use third-party analytics tools, advertising identifiers or tracking cookies.

6.5. The Operator keeps personal data confidential and does not disclose it to third parties without the user’s consent, except as set out in Section 7 and as required by the laws of the Russian Federation (Article 7 of the Personal Data Law).

7. Disclosure to third parties. Cross-border transfer

7.1. Personal data is disclosed only to the extent necessary for the purposes of processing:

RecipientDataPurposeCountry
Educational institution (EIOS)EIOS login and password, requests for grades and certificatesSigning in to EIOS at the user’s instruction. Requests go through a proxy server in the Russian Federation over HTTPSRussian Federation
TelegramUser ID and username, bot messagesSign-in with Telegram, notificationsOutside the Russian Federation (Telegram infrastructure)
VK (VK LLC)User ID, nameSign-in with VKRussian Federation
Apple Inc.Apple ID identifier; push tokenSign-in with Apple, notification delivery (APNs)United States
OSRM routing service (router.project-osrm.org)Route start and end coordinatesRoute planning at the user’s requestGermany
2GIS, Yandex Maps, Google Maps, Apple Maps — as chosen by the userRoute coordinates or addressOpening the route in the chosen serviceDepends on the chosen service
Hosting providersAll data stored on the Service’s serversHosting the serversNetherlands (main server), Russian Federation (auxiliary server)
Public authoritiesAs required by lawCompliance with the lawRussian Federation

7.2. The Service’s main server is located in the Kingdom of the Netherlands. An auxiliary server that forwards mini app requests is located in the Russian Federation (Novosibirsk).

7.3. The Netherlands is a party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data and is among the states providing adequate protection of the rights of data subjects (Article 12(1) of the Personal Data Law). Cross-border transfer is carried out in the manner established by Article 12 of the Personal Data Law.

7.4. Class schedules and information about rooms and teachers are obtained from publicly available sources of educational institutions. Map data © OpenStreetMap contributors.

8. Retention periods

DataPeriod
Account data, notes, attendance dataUntil the account is deleted or consent is withdrawn
Database backups (stored encrypted)No more than 30 days from creation
Server logs (IP address, request time and path)No more than 7 days
Server cache of grades and certificate requestsNo more than 10 minutes
Attendance journal export file (for group leaders)No more than 15 minutes
Aggregated statistics not linked to usersNo time limit

8.2. Upon deletion of the account or withdrawal of consent, personal data is destroyed within a period not exceeding 30 days (Article 21(5) of the Personal Data Law), unless otherwise required by federal law.

9. User rights

9.1. The user has the right to (Articles 14, 20 and 21 of the Personal Data Law):

9.2. The user can delete the account and manage data processing in the Service settings — see Privacy Choices.

9.3. Requests should be sent to the Operator by email at timora-supp@yandex.ru or via Telegram @y0rence. A request must contain information that allows the user to be identified in the Service (for example, the Timora profile number or the linked Telegram account). The Operator responds within 10 business days of receiving a request; this period may be extended by no more than 5 business days with a reasoned notice (Article 14(3) and Article 20 of the Personal Data Law).

10. Security measures

10.1. The Operator takes legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision and dissemination (Articles 18.1 and 19 of the Personal Data Law), including:

10.2. Only the Operator and persons authorised by the Operator who are bound to keep it confidential have access to personal data.

10.3. Upon discovering an unlawful or accidental transfer of personal data that has violated users’ rights, the Operator notifies Roskomnadzor within 24 hours of discovering the incident and, within 72 hours, of the results of its investigation (Article 21(3.1) of the Personal Data Law), and takes measures to eliminate its consequences.

11. Personal data of minors

The Service is intended for students of educational institutions and is not directed at persons under 14 years of age. The Operator does not knowingly process personal data of persons under 14. A legal representative who becomes aware that such data has been provided may contact the Operator to have it destroyed.

12. Advertising

12.1. The Service displays advertising banners. Advertising is not personalised: personal data is not used to select ads and is not shared with advertisers. The Operator counts only the aggregated number of impressions and clicks for each banner.

12.2. The user can turn off advertising in the Service settings.

13. Changes to the Policy

13.1. The Operator may amend this Policy. A new version takes effect upon publication at the address specified in clause 1.5, unless the new version provides otherwise.

13.2. The Operator notifies users of material changes within the Service at least 10 days before they take effect.

14. Final provisions

14.1. Relations between the user and the Operator arising in connection with the processing of personal data are governed by the laws of the Russian Federation.

14.2. Timora is independent software and is not an official application of any educational institution.