of the website start.vixgreex.com and the Telegram bot @vixgreex_start_bot
Version 1.0 of 27 October 2026. It takes effect from the date of publication on the website.
Published on the website: 10 November 2026
The entity responsible for the processing of personal data (the controller) is THE A CONSULTING OÜ, registration code 16641310, address: Kanali tee 6, 10112 Tallinn, Estonia. The company runs the VIX&GreeX school and owns this website and the Bot.
Email for questions regarding personal data: vixgreex@gmail.com. To help us process your message faster, indicate “Personal data” in the subject line.
This Privacy Policy (hereinafter — the “Policy”) applies to the processing of personal data during the use of the website start.vixgreex.com (hereinafter — the “Site”) and the Telegram bot @vixgreex_start_bot (hereinafter — the “Bot”). The main website vixgreex.com has a separate Privacy Policy. Telegram and YouTube process personal data in accordance with their own privacy policies; the specifics of interaction with these platforms are described in section 6 of this Policy.
Personal data are processed in accordance with the General Data Protection Regulation of the European Union (GDPR) and the applicable legislation of Estonia. The personal data protection standards provided for by the GDPR apply to all users regardless of the country in which they are located, taking into account other mandatory requirements of legislation that may apply to the relevant legal relations.
| What data | Why | Legal basis | How long we keep them |
|---|---|---|---|
| Technical hosting logs: IP address, browser and device type, address of the requested page, date and time of the request | To display the page, to ensure the operation and security of the website, and to investigate failures and attacks | Legitimate interests — Art. 6(1)(f) GDPR | 7–30 days (depends on the hosting plan) |
| Our own visit counter: only the name of the event (for example, “page opened” or “bot button pressed”) and the time. No cookies and no separate user identifiers | General visit statistics | Legitimate interests — Art. 6(1)(f) GDPR | Kept in the form of aggregated visit statistics not linked to specific users. |
| Your choice in the cookie banner | Storing your settings and taking into account consent given or withdrawn | Legal obligation to take consent into account — Art. 6(1)(c) GDPR | 12 months in your browser |
| Google Analytics 4 (only with “Analytics” consent): a pseudonymous identifier of the browser in a cookie, pages viewed and clicks, time on the website, referral source (including the advertising campaign), device and browser type, language, approximate location (country, city) | Traffic analysis and improvement of the Site | Your consent — Art. 6(1)(a) GDPR | Cookies — 13 months. Data in Google Analytics — 14 months |
| Google Ads — conversion tracking (only with “Advertising” consent): the ad click identifier and related cookies, the fact of a click-through to the Bot, the time | Evaluating the effectiveness of advertising and click-throughs to the Bot, without remarketing or personalised advertising | Your consent — Art. 6(1)(a) GDPR | Cookies — up to 90 days |
| YouTube video testimonials: when you click on a video, YouTube (Google) receives your IP address and browser data and may set its own cookies. Before the click, no request is sent to YouTube: the preview is loaded from our server | Playback of the video you have chosen | Your consent, expressed by clicking on the video — Art. 6(1)(a) GDPR | Determined in accordance with Google’s privacy policy |
According to Google, Google Analytics 4 does not store IP addresses: the IP address is used only to determine the approximate location.
Google Analytics and Google Ads are used only after the relevant consent has been obtained in the cookie banner. Until consent is obtained, the relevant tags are not loaded.
YouTube video testimonials are loaded only after you have made your choice. Until then, the video preview is displayed from our server without any data being transferred to YouTube.
| What data | Why | Legal basis | How long we keep them |
|---|---|---|---|
| Telegram profile data: Telegram ID, first name (and last name, if provided), username, interface language, as well as the profile photo, if the Bot receives it. Telegram transfers the basic profile data to the Bot after “Start” is pressed. | To provide lessons and guides; identification of the user during interaction with the Bot | Performance of a contract on free access to the lessons — Art. 6(1)(b) GDPR | For as long as you use the Bot; we delete them after 12 months of inactivity or earlier at your request |
| Correspondence with the Bot: your messages, button presses and the Bot’s replies | To provide materials, answer questions and help with problems | Performance of a contract — Art. 6(1)(b) GDPR | Same as profile data |
| Referral source: the tag of the link by which you came to the Bot (for example, from the website or from YouTube) | Analysis of the effectiveness of user acquisition channels | Legitimate interests — Art. 6(1)(f) GDPR | Same as profile data |
| Information on consent to the promotional mailing: the answer “Yes” or “No”, date and time, withdrawal of consent | Sending promotional messages with the user’s consent and confirming that it has been obtained | For the mailing — consent, Art. 6(1)(a) GDPR; for keeping evidence of consent — compliance with a legal obligation, Art. 6(1)(c) and 7(1) GDPR | Records of the giving and withdrawal of consent — for as long as it is in effect and for 3 years after its withdrawal or the termination of the promotional mailing. Information on a refusal of the mailing without consent having previously been given is kept for as long as the Bot is used. |
| Your requests regarding personal data: correspondence and the data needed to identify you | Handling requests and ensuring the exercise of users’ rights | Legal obligation — Art. 6(1)(c) GDPR | 3 years after the reply is provided |
The Bot does not ask for an email address, phone number or payment details. At the same time, we may process information that you yourself provide in your messages.
We do not request and do not intend to collect special categories of personal data. Please do not send such information via the Bot. If such data have been provided by a user without our request, we do not use them for separate purposes and take measures to delete them if there is no legal basis for their further retention.
We do not take decisions that have legal or similarly significant effects for you solely on the basis of automated processing of personal data.
Service messages. Lessons, guides and reminders about them are received by users who have pressed “Start” and have themselves requested the learning materials. Such messages do not contain promotional offers.
Promotional messages. Invitations to live sessions and paid courses are sent only with your separate consent, given by pressing the button “Yes, send me invitations to live sessions and courses”. If you have answered “No” or have not given consent, promotional messages will not be sent. This rule also applies to users who started using the Bot earlier.
How to unsubscribe:
You can also block the Bot in Telegram to stop receiving all messages. To withdraw consent to the promotional mailing, use the /stop command or the corresponding button in the Bot menu.
After unsubscribing via /stop or the Bot menu, access to the learning materials is retained. Withdrawal of consent does not affect the lawfulness of the processing of personal data carried out before its withdrawal.
If you wish to have your personal data deleted, contact us via the Bot or at the email address vixgreex@gmail.com.
Cookies and similar technologies are used on the Site. Cookies that are set directly on the Site are valid only on the domain start.vixgreex.com and are not linked to the cookies of the main website vixgreex.com. After a YouTube video is started, the cookies of that platform may be used.
| Name | Category | Purpose | Duration |
|---|---|---|---|
| Record of the choice in the cookie banner | Necessary (operate without consent) | Stores your choice | 12 months |
| vg_ga | Analytics (only with consent) | Google Analytics: distinguishes browsers | 13 months |
| vg_ga_6XV8Z174T4 | Analytics (only with consent) | Google Analytics: stores the session state | 13 months |
| _gcl_au and other Google Ads cookies used for conversion tracking. | Advertising (only with consent) | Tracking of click-throughs from advertising to the Bot. | Up to 90 days |
How to give consent, refuse or change your choice. On your first visit, a banner appears with the buttons “Accept”, “Reject” and “Customise”. In “Customise” you can allow “Analytics” and “Advertising” separately. You can change your choice at any time via the “Cookie settings” link at the bottom of every page. If you withdraw consent, the sending of data to Google stops and the Google cookies are deleted. You can also delete cookies through your browser settings.
We use Google Consent Mode v2 in its basic implementation: until the relevant consent is obtained, Google’s analytics and advertising tags are not loaded.
Our contractors acting as processors. To ensure the operation of the Site and the Bot, we engage service providers that process personal data on our instructions and in accordance with the applicable contractual terms:
Independent controllers. Certain platforms independently determine the purposes and means of the processing of personal data in accordance with their own privacy policies:
Our team. Access to the personal data of the Bot is granted only to authorised employees and engaged contractors of THE A CONSULTING OÜ who need such information to administer the Bot and provide support to users. They are obliged to ensure the confidentiality of personal data.
Public authorities and courts may receive personal data in the cases provided for by applicable law.
We do not sell personal data and do not transfer them to partners or advertisers for their own marketing purposes.
In connection with the use of third-party services, your personal data may be transferred outside the European Economic Area (EEA), in particular to the USA. To ensure appropriate protection of personal data, the following legal mechanisms are applied:
Telegram is an independent controller of the personal data of its platform and determines the conditions of their storage and international transfer in accordance with its own privacy policy.
A copy of the applicable safeguards for the protection of personal data in international transfers, or information about them, can be obtained by contacting us at the email address given in section 1 of this Policy.
After the period expires, the data are deleted or anonymised. Data may be kept longer if this is required by law or is necessary for the establishment, exercise or defence of legal claims.
Under the GDPR, you have the right to:
How to exercise your rights. To exercise these rights, contact us at the email address vixgreex@gmail.com or via the Bot. To enable your data in the Bot to be identified, we recommend contacting us from the same Telegram account that was used previously. Where there are reasonable doubts as to the identity of the applicant, we may request additional information necessary to confirm their identity.
We handle a request without undue delay, but no later than one month from the day it is received. Where necessary, this period may be extended by a further two months, taking into account the complexity and number of requests. We will inform you of the extension of the period and the reasons for it within the first month. The handling of requests is usually free of charge, except in the cases provided for by law.
Where to lodge a complaint. If you believe that the processing of your personal data infringes the requirements of the law, you have the right to contact the Estonian supervisory authority for the protection of personal data — Andmekaitse Inspektsioon (Tatari 39, 10134 Tallinn, Estonia; info@aki.ee; www.aki.ee). You may also lodge a complaint with the competent supervisory authority of the EEA state in which you habitually reside, work or where the alleged infringement took place.
We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration or unlawful disclosure in accordance with Art. 32 GDPR.
Access to the data is granted only to authorised persons who need it to perform their duties. The Site uses a secure HTTPS connection. When engaging third-party service providers, we take their security measures into account and ensure appropriate contractual safeguards for the protection of personal data.
The Site and the Bot are intended exclusively for persons who have reached the age of 18. We do not knowingly collect personal data of minors. If we become aware that personal data of a person under the age of 18 have been obtained, we will take measures to delete them, except where further retention is required by law.
We may update this Policy from time to time, in particular in connection with changes in legislation, in the procedure for processing personal data or in the services used. The updated version is published on the Site with an indication of the date on which it takes effect. We will also notify you of material changes via the Bot or by another available means. If the changes require new consent to be obtained, we will request it before the relevant processing begins.
This Policy is available in Ukrainian, Russian and English. In the event of discrepancies between the language versions, the Russian version shall prevail, unless otherwise provided by mandatory requirements of applicable law.