1. Roles
The customer is the controller of its user and recipient data. PRUSSO LLC processes recipient identifiers on documented customer instructions. PRUSSO LLC remains an independent controller for its own account, payment, and security data.
2. Scope
Processing covers recipient email and VK or Telegram identifiers, external user ID, request metadata, and delivery or verification status for routing, delivery, billing, support, and security. Special-category, biometric, and child data must not be submitted without separate written approval and a lawful basis.
3. Duties
- The customer establishes lawful grounds and notices.
- OTPilot follows documented instructions and applies confidentiality and security controls.
- OTPilot reports confirmed incidents without undue delay.
- Infrastructure providers and customer-selected channels may act as subprocessors or independent recipients.
- Data is deleted or returned after the instruction ends unless retention is required by law.