Privacy Policy

Who are we

RHYTHMS NOTHING is a project created byKonstantin ShelAndNatalia Morozovatogether with a technology partnerNeiry LLCand a number of partners in the field of neurotechnology and research infrastructure.

We conduct research into controlled states of consciousness using EEG equipment, proprietary methodologies and digital tools. Program participants are real people to whom we entrust our data. This trust is not a formality for us.

Legal entity:_________________________ (in the process of registration)

For all questions:@konstantinshell

1. What data we collect

We collect only what is really needed for the program to work.

Data that you provide to us yourself:

• Name, contact details, Telegram account
• Information you enter into questionnaires, diaries and program assignments
• Data you transmit during sessions and communications within the program

Data that is collected automatically:

• Telegram ID and account name at the time of acceptance of agreements
• Date and time of acceptance
• Technical data on interaction with the bot (without monitoring personal correspondence)

Research data:

• Results of EEG measurements in anonymized form
• Phenomenological reports and data on states of consciousness
• Survey data as part of research protocols

2. Why do we need this data?

We use your data strictly for the following purposes:

• Conducting the program— organization of sessions, communication with participants, access to materials
• Research— formation of an anonymized neurophysiological data base for methodology verification
• Personalization— creation of individual AI reports and analytics for your conditions
• Legal fixation— confirmation of the acceptance of agreements
• Program improvement— analysis of results for the development of methodology

3. Who do we transfer data to?

We transfer data only within the framework necessary for the operation of the program:

Neiry LLC— in terms of technical data of EEG equipment and software necessary for conducting the study.

Anthropic PBC (USA, Claude model) — the text of your entries, test results and device metrics is temporarily sent to the Claude model to compose your AI reports. Audio is never sent, only transcribed text. Anthropic does not receive your name or contacts separately from the task text and does not sell data. This is a cross-border transfer — see 3a.

Telegram Messenger Inc. — all communication with the bot, voice messages and files pass through Telegram servers under Telegram's own rules. Payments are processed by Telegram; we never see your card.

GitHub Inc. (USA) — hosting of exnihilo.life and of personal profile pages. Your profile page (reports, charts, test results) is built on the team's own hardware and published on this host under a personal non-public link; search indexing of profiles is disallowed. Raw data (entries, audio, device files) is not stored at the host.

Yandex LLC (Russia) — Yandex.Metrica on the website only: visits, clicks, anonymised session replay (Webvisor). Not in the bot.

Tracker vendors (Garmin, WHOOP, Suunto, NEYROX) — we send them nothing; we fetch your data from their cloud with your permission. Your vendor login and password are stored encrypted and used only for syncing.

Your master — if you work with a program master, they see your data only after you confirm the link in the bot. No access before that.

Government bodies- exclusively as required by law, on the basis of an official request.

3a. Cross-border transfer

Part of the processing happens on servers outside Russia: Anthropic PBC (USA) for AI reports, Telegram Messenger Inc. for bot communication, GitHub Inc. (USA) for hosting the built profile page. The USA is not on the list of countries with adequate data protection, so the transfer is based on your written-form consent (art. 12 part 10 item 1 of Federal Law 152-FZ). We send the minimum, never audio, keep raw data in Russia on our own hardware, and do not train AI models on your data ourselves. Without this consent, participation with AI reports is not possible; you may withdraw it at any time.

4. Research data - separately

This is an important point. EEG data and research results:

• Stored and processed inimpersonal form— without reference to your name and contacts
• Used exclusively for scientific purposes within the framework of the program
• Not published publicly without your separate consent
• When publishing scientific results - only in aggregated, anonymous form

5. How we store data

• Raw data (entries, audio, device files, database) is stored locally on the team's own encrypted hardware in Russia, not in a public cloud. The built profile page is hosted on GitHub Pages under a personal non-public link and can be unpublished on request
• Access to personal data is available to a limited circle of persons directly working with the program
• We take technical and organizational measures to protect data from leakage, loss and unauthorized access
• In the event of a security incident, we will notify you within a reasonable time

6. How long do we store data?

• Program participant details— during the period of participation and 3 years after its completion
• Agreement acceptance data— 5 years (legal necessity)
• Anonymized research data— indefinitely, as part of the scientific base
• According to your request— we delete personal data within 30 days, unless this contradicts the requirements of the law

7. Your rights

You have the right at any time:

• Requesta copy of the personal data we hold about you
• To correctinaccurate data
• Deleteyour personal data - we will fulfill the request within 30 days
• Withdraw consentfor data processing - this does not entail automatic termination of the non-disclosure agreement
• Get confirmationthe fact and time of acceptance of your agreements

To exercise any of these rights, write to us directly:@konstantinshell

8. Legal basis

This Policy has been developed in accordance with:

• Federal Law No. 152-FZ “On Personal Data”
• Federal Law No. 98-FZ “On Trade Secrets”
• Civil Code of the Russian Federation

Legal grounds: your consent (art. 6 part 1 item 1 of 152-FZ); for health data — written-form consent (art. 10 part 2 item 1); for transfer to countries without adequate protection — written-form consent (art. 12 part 10 item 1); for payment facts — performance of a contract. Consent is given in the Telegram bot by pressing "I agree" under the consent text, before any data is collected; pressing the button from your phone-verified Telegram account is your simple electronic signature (Federal Law 63-FZ), which makes the consent written-form. Consent is a single, separate document (not part of the Terms, offer or NDA) covering personal data, health data and the cross-border transfer; the bot's service messages are part of the program and need no separate consent. The service is for persons over 18. AI reports are generated by the Claude model, may contain errors and are not medical or professional advice. We do not train AI models on your data; how Anthropic handles received text is governed by Anthropic's terms.

9. Policy changes

If we make changes, you will be the first to know about it. The notification comes through a Telegram bot. All changes are recorded in the update history below with the date and description of what has changed.

If the changes are significant, we will ask you to accept the updated version separately.

📋 Update history

All changes are recorded publicly. Nothing changes without your knowledge.