Privacy Policy
Last Updated: January 13, 2026
Introduction
INITE Club ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website inite.club and use our services.
This policy complies with:
GDPR (General Data Protection Regulation - EU)
CCPA (California Consumer Privacy Act - USA)
FZ-152 (Federal Law on Personal Data - Russia)
By using our services, you agree to the collection and use of information in accordance with this policy.
1. Information We Collect
1.1 Personal Information
We collect information that you provide directly to us:
Account Information: Name, email address, country, city
Profile Information: Telegram username, LinkedIn profile, professional background
Onboarding Data: Current goals, skills, interests, INITE Flow block preferences
Path Data: Progress entries, goal updates, challenges completed
Communication Data: Messages with AI Manager, chat history, feedback
1.2 Automatically Collected Information
When you use our services, we automatically collect:
Device Information: Browser type, operating system, device identifiers
Usage Data: Pages visited, features used, time spent, click patterns
Location Data: IP address, general geographic location (country/city level)
Cookies and Tracking: See our Cookie Policy below
1.3 Third-Party Information
We may receive information from:
OAuth Providers: When you sign in via social accounts
Analytics Services: Aggregated usage statistics
Public Sources: Publicly available professional information (e.g., LinkedIn)
2. How We Use Your Information
We use collected information for:
2.1 Core Services
Account Management: Creating and maintaining your account
Personalization: Tailoring AI recommendations and content
Path Tracking: Monitoring your progress through INITE Flow
Community Features: Connecting you with other members
Event Management: RSVP handling and event notifications
2.2 Communication
Service Updates: Important announcements and changes
Event Notifications: Reminders about upcoming events
AI Interactions: Personalized guidance from AI Manager
Community Updates: News from INITE ecosystem
2.3 Analytics & Improvement
Usage Analysis: Understanding how users interact with our platform
Performance Monitoring: Identifying and fixing technical issues
Feature Development: Building new features based on user needs
A/B Testing: Testing improvements to user experience
2.4 Legal Compliance
Legal Obligations: Complying with applicable laws and regulations
Safety & Security: Preventing fraud, abuse, and security incidents
Rights Protection: Protecting our rights and property
3. Cookie Policy
3.1 What Are Cookies?
Cookies are small text files stored on your device that help us recognize you and remember your preferences.
3.2 Types of Cookies We Use
Essential Cookies (Always Active)
Authentication: Keeping you logged in
Security: Preventing fraud and protecting your account
Preferences: Remembering your language and settings
Cookie Consent: Storing your cookie preferences
Analytics Cookies (Optional)
Google Analytics: Understanding website usage and traffic patterns
Yandex.Metrika: Analyzing user behavior and site performance
Heatmaps: Visualizing how users interact with pages
Functional Cookies (Optional)
Video Embeds: YouTube, Vimeo player functionality
Social Media: Social sharing features
Chat Widget: Support chat functionality
3.3 Managing Cookies
You can control cookies through:
Cookie Banner: Accept or decline optional cookies
Browser Settings: Block or delete cookies
Opt-Out Tools: Google Analytics opt-out, Do Not Track
Note: Disabling essential cookies may affect website functionality.
4. Data Sharing and Disclosure
4.1 We Share Your Information With:
Service Providers
Authentication: OAuth providers (Google, Microsoft, etc.)
Analytics: Google Analytics, Yandex.Metrika
Hosting: Vercel, cloud infrastructure providers
Database: PostgreSQL hosting services
AI Services: OpenAI for AI Manager functionality
Legal Requirements
We may disclose information when required by:
Legal process (subpoena, court order)
Government requests
Protection of rights and safety
Prevention of fraud or abuse
Business Transfers
In case of merger, acquisition, or sale, your information may be transferred to the new entity.
4.2 We Do NOT:
❌ Sell your personal information to third parties
❌ Share your data with advertisers
❌ Use your data for targeted advertising
❌ Disclose your information without consent (except legal requirements)
5. Data Security
5.1 Security Measures
We implement industry-standard security practices:
Encryption: HTTPS/TLS for data in transit
Access Controls: Role-based access to sensitive data
Authentication: OAuth2 + PKCE, passkey support
Monitoring: Automated security monitoring and alerts
Regular Audits: Security reviews and vulnerability assessments
5.2 Your Responsibility
Use strong, unique passwords
Enable two-factor authentication
Keep your login credentials confidential
Report suspicious activity immediately
5.3 Data Breach Notification
In case of a security breach affecting your personal data, we will notify you within 72 hours as required by GDPR.
6. Data Retention
6.1 How Long We Keep Your Data
Account Information
While account is active + 30 days after deletion
Path & Progress Data
While account is active + 90 days after deletion
Chat & AI History
2 years or until account deletion
Analytics Data
Aggregated data retained indefinitely
Logs & Security Data
12 months
Cookie Consent Records
12 months
6.2 Account Deletion
You can request account deletion at any time. Upon deletion:
Personal information is permanently removed within 30 days
Anonymized data may be retained for analytics
Backups may contain your data for up to 90 days
Legal obligations may require longer retention
7. Your Rights
7.1 GDPR Rights (EU Users)
Right to Access: Request a copy of your personal data
Right to Rectification: Correct inaccurate information
Right to Erasure: Request deletion of your data ("right to be forgotten")
Right to Restriction: Limit how we process your data
Right to Portability: Receive your data in a portable format
Right to Object: Object to processing of your data
Right to Withdraw Consent: Withdraw consent at any time
Right to Lodge a Complaint: File a complaint with supervisory authority
7.2 CCPA Rights (California Users)
Right to Know: What personal information we collect and how it's used
Right to Delete: Request deletion of personal information
Right to Opt-Out: Opt-out of sale of personal information (we don't sell data)
Right to Non-Discrimination: Equal service regardless of privacy choices
7.3 FZ-152 Rights (Russia Users)
Right to Information: Know what data is processed and why
Right to Access: Access your personal data
Right to Correction: Correct inaccurate data
Right to Block: Block processing of inaccurate data
Right to Delete: Request deletion of personal data
Right to Withdraw Consent: Withdraw consent for data processing
7.4 How to Exercise Your Rights
Contact us at: [email protected]
We will respond to requests within:
30 days (GDPR)
45 days (CCPA)
10 days (FZ-152)
8. Children's Privacy
INITE Club is not intended for children under 16 years old. We do not knowingly collect personal information from children. If we discover that a child under 16 has provided us with personal information, we will delete it immediately.
If you believe a child has provided us with personal information, please contact us at: [email protected]
9. International Data Transfers
9.1 Data Location
Your data may be processed and stored in:
European Union: Primary data center location
United States: Cloud services and analytics
Russia: For users located in Russia (FZ-152 compliance)
9.2 Transfer Safeguards
We ensure adequate protection through:
Standard Contractual Clauses (EU-approved)
Privacy Shield Framework (where applicable)
Local Data Residency (for Russia users per FZ-152)
Encryption for all data transfers
10. AI and Automated Decision-Making
10.1 AI Manager
Our AI Manager uses your data to:
Provide personalized recommendations
Track your progress through INITE Flow
Suggest relevant connections and events
Generate insights about your journey
10.2 Human Oversight
No purely automated decisions affect your membership
All significant decisions involve human review
You can challenge AI recommendations
You can opt-out of AI-powered features
10.3 AI Data Processing
AI interactions are encrypted
Chat history is stored securely
AI models are trained on anonymized data
We do not use your data to train third-party AI models
11. Third-Party Links
Our website may contain links to third-party websites:
We are not responsible for their privacy practices
We recommend reviewing their privacy policies
Links do not imply endorsement
12. Updates to This Policy
We may update this Privacy Policy periodically. Changes will be:
Posted on this page with updated "Last Updated" date
Notified via email for material changes
Requiring consent for significant changes
Continued use after changes constitutes acceptance of the updated policy.
13. Contact Us
Privacy Inquiries
Email: [email protected]
Data Protection Officer (GDPR)
Email: [email protected]
General Contact
Website: https://inite.club Telegram: @initeclub
Mailing Address
INITE Club [Your Business Address] [City, Country, Postal Code]
14. Legal Information
Data Controller
INITE Club is the data controller responsible for your personal information.
Legal Basis for Processing (GDPR)
We process your data based on:
Consent: You've given explicit consent
Contract: Necessary for providing our services
Legal Obligation: Required by law
Legitimate Interests: Improving our services, preventing fraud
Supervisory Authorities
EU: Your local Data Protection Authority
California: California Attorney General
Russia: Roskomnadzor
15. Cookie Consent Management
You can manage your cookie preferences at any time by:
Clearing your browser's localStorage for
cookie-consentAdjusting browser settings to block cookies
Using our cookie preference center (coming soon)
Acknowledgment
By using INITE Club, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.
Questions? Contact us at [email protected]
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