Privacy Policy

Version of 24 June 2026 · Effective date: 24 June 2026

This Privacy Policy (the “Policy”) describes what personal data is processed when you use the “Soluno” application and service, for what purposes, on what legal grounds, to whom the data may be disclosed, and what rights the user has. The Policy has been prepared in accordance with Federal Law of the Russian Federation No. 152-FZ of 27 July 2006 “On Personal Data”.

1. General provisions and definitions

“Service”, “Soluno” — the mobile application for iOS and Android, as well as the web account available at app.soluno.ru, which together constitute a Russian-language companion for the WHOOP fitness tracker.

“Operator” — the person who organises and carries out the processing of personal data (details are set out in sections 2 and 12).

“User” — an individual who uses the Service.

“Personal data” — any information relating to a directly or indirectly identified or identifiable User.

“Processing of personal data” — any operation performed on personal data: collection, recording, organisation, storage, use, transfer, deletion, etc.

“WHOOP” — the fitness tracker and service of WHOOP, Inc., to the account of which the User connects Soluno on their own initiative through the official authorisation interface (OAuth).

Use of the Service constitutes the User’s acceptance of this Policy. If the User does not agree with the terms of the Policy, the User must stop using the Service.

2. Operator and contacts

The operator of personal data is:

Individual Entrepreneur Brovkin Andrey Aleksandrovich (Russian sole proprietor, “Индивидуальный предприниматель Бровкин Андрей Александрович”)
INN (taxpayer identification number) 780537810433, OGRNIP (state registration number of an individual entrepreneur) 322784700057311
Address: 198207, Russia, St. Petersburg, Prospekt Stachek 170, apt. 10
E-mail for data processing enquiries: hello@soluno.ru

3. What personal data is processed

The Operator processes the following categories of data.

3.1. Health data and physiological indicators (special category)

Received from the User’s WHOOP account through the official WHOOP API after the User has connected their own account:

• Recovery, including zones;
• sleep data: stages, duration, Sleep Need, sleep debt;
• Strain and workouts;
• heart rate and heart rate variability (HRV);
• resting heart rate (RHR), respiratory rate;
• blood oxygen saturation (SpO₂), skin temperature;
• other physiological indicators provided by the WHOOP API.

3.2. Account and identification data

• WHOOP user identifier, authorisation tokens (OAuth) required to access the data;
• name / profile data, if provided by the WHOOP API;
• e-mail address (when contacting support or for notifications);
• subscription and payment history data (the fact, date, amount and period of payment).

3.3. Technical data

• device type and version, operating system, application version;
• IP address, technical session identifiers;
• error logs and application events (for diagnostics).

3.4. AI coach data

The text of your requests to the AI coach and the corresponding metrics on the basis of which the response is generated. The processing is carried out by the model provider (see section 6).

4. Purposes of processing

• providing the functionality of the Service: displaying WHOOP data in Russian;
• operation of the AI coach, which generates recommendations based on your metrics;
• identification and authorisation of the User, providing access to the account;
• arranging and maintaining the subscription, accepting and recording payments;
• technical support, handling enquiries sent to hello@soluno.ru;
• ensuring the operability, security and stability of the Service;
• compliance with the requirements of the legislation of the Russian Federation.

5. Legal grounds and consent

Personal data is processed on the following grounds:

• the User’s consent to the processing of personal data (art. 6 of Law No. 152-FZ);
• performance of the contract (public offer) to which the User is a party;
• performance of the obligations imposed on the Operator by law.

6. Disclosure to third parties and cross-border transfer

The Operator does not sell personal data. Data is transferred only to the extent necessary for the operation of the Service, to the following categories of recipients:

• WHOOP, Inc. — the source of the data. The User connects their WHOOP account on their own initiative; the data exchange takes place through the official WHOOP API on WHOOP’s terms.
• Anthropic — processing of AI coach requests. This may involve a cross-border transfer of data outside the Russian Federation; the text of the request and the related metrics are transferred to the extent necessary to generate a response.
• YooMoney LLC (the YooKassa service) — acceptance and processing of payments. Bank card payment data is processed directly by YooKassa; Soluno neither receives nor stores it.
• Hosting provider — hosting and technical support of the Service’s operation.

Cross-border transfer is carried out in compliance with the requirements of Law No. 152-FZ. By using the AI coach, the User consents to such transfer to the stated extent and for the stated purposes.

7. Retention periods

Personal data is stored for the duration of the use of the Service and the term of the subscription, as well as for the periods established by law (in particular, for payment and accounting data). Once the purposes of processing have been achieved, upon withdrawal of consent, or upon a deletion request, the data is deleted or anonymised, unless otherwise provided by law. Authorisation tokens are stored until the WHOOP account is disconnected or access is revoked by the User.

The recording, organisation, accumulation and storage of the personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation (part 5 of art. 18 of Federal Law No. 152-FZ).

8. Rights of the data subject

The User has the right to:

• obtain information about the processing of their personal data;
• request the rectification, blocking or deletion of data if it is incomplete, outdated, inaccurate or processed in breach of the law;
• withdraw consent to the processing of personal data, including the processing of health data;
• request that processing be stopped and the data deleted;
• appeal against the Operator’s actions to the authorised body (Roskomnadzor) or in court.

To exercise any of these rights, send a request to hello@soluno.ru. The Operator reviews the request and provides a response within the time limits established by law. Access to WHOOP data can also be revoked by disconnecting the application in the settings of your WHOOP account.

9. Cookies and analytics

The web account may use cookies and similar technologies that are necessary for authorisation, session persistence and basic analytics of the Service’s operation. Most cookies can be managed in your browser settings; disabling certain cookies may limit the functionality of the web account. The mobile application uses technical identifiers for authorisation and diagnostics.

10. Security measures

The Operator takes legal, organisational and technical measures to protect personal data against unlawful access, alteration, disclosure or destruction: transmission of data over secure channels (HTTPS), restricted employee access, and storage of authorisation tokens in protected form. Card payment data is processed on the side of a certified payment provider (YooKassa).

11. Changes to the Policy

The Operator has the right to amend this Policy. The current version is always published at soluno.ru/privacy.html, stating the effective date. Continued use of the Service after any changes constitutes acceptance of the updated Policy.

12. Operator details

See also: Public offer · Home · Русская версия