This Privacy Policy ("Policy") governs the collection, storage, processing and protection of personal data of users interacting with the chatbot and automated support system provided by Individual Entrepreneur Dmitrii Poliakov operating under the Nercy platform (hereinafter — "Operator", "we").
By using our service via Telegram, Instagram or other connected channels, you agree to the terms of this Policy. If you do not agree, please discontinue use of the service.
When interacting with our chatbot, we automatically receive and process the following categories of data:
We process your data exclusively for the following purposes:
Data processing is carried out on the following legal grounds:
| Legal basis | Application |
|---|---|
| Performance of a contract Art. 6(1)(b) GDPR |
Processing orders, ticket sales, delivering the purchased product |
| Legitimate interest Art. 6(1)(f) GDPR |
Fraud detection, service quality improvement, conversation history for continuity |
| Consent Art. 6(1)(a) GDPR |
Voluntarily initiating a dialogue with the bot constitutes consent to data processing for service provision purposes |
To provide the service, we use the following sub-processors and partners to whom part of your data may be transferred:
| Sub-processor | Purpose |
|---|---|
| Chatwoot | Storing conversation history and managing dialogues (customer support platform) |
| Pretix | Ticketing system: creation, storage and management of tickets and orders; storage of event information (name, date, venue, price, capacity); buyer identification data linked to orders (name, email); QR code generation |
| Telegram / Meta (Instagram) | Delivering messages via their API in accordance with their own privacy policies |
| AI model providers | Analysing message text to generate responses (data is passed in anonymised dialogue context) |
| n8n | Technical processing of automation workflows |
| Acquiring bank | Processing ticket payments via a secure bank link (card data is not stored by Nercy) |
Cross-border data transfer: the platform infrastructure is hosted on servers located in the United States (North Carolina). Data transfer to the US is carried out with appropriate safeguards in accordance with applicable law.
Data about the dialogue state is stored in the service's internal database on servers located in the United States (North Carolina).
| Data type | Retention period |
|---|---|
| Active dialogues | Throughout the entire service period |
| Completed dialogues | No more than 12 months from the date of last activity |
| Transaction data (ticket purchases) | In accordance with Georgian financial legislation requirements (up to 7 years) |
Upon expiry of the retention period, data is deleted or anonymised.
Our service uses automated message processing, including:
If you believe an automated decision was made in error in relation to you, you have the right to request a review with the participation of a live operator by contacting us via the details in section 10.
You have the following rights regarding your data:
To exercise any of these rights, contact us via the details in section 10.
We apply technical and organisational measures to protect your data from unauthorised access, alteration, disclosure or destruction, including:
For all questions related to the processing of personal data, as well as to exercise your rights, please contact us:
Nercy — Individual Entrepreneur Dmitrii Poliakov
Georgia, Tbilisi, Petre Iberi street 11, ap. 75
Tax ID: 305811342
Email: wospdp13@gmail.com
Telegram: @Nik_Ly
Tel: +995 598 58 10 32
Data Protection Officer (DPO): not designated (the Operator does not meet the thresholds for mandatory DPO appointment under Art. 37 GDPR).
We reserve the right to amend this Policy. The current version is always available at: nercy.org/privacy.html
In the event of material changes (affecting data processing rights, new sub-processors, or change of applicable law), we will notify users through the interaction channel. Continued use of the service after publication of changes constitutes acceptance of the updated Policy.