Last Updated: October 23, 2026
This Privacy Policy explains how PRIME RADIANT LLC ("Company," "We," "Us," or "Our") collects, uses, shares, and otherwise processes your personal data and your rights regarding your personal data.
PRIME RADIANT LLC is the owner and provider of the ReplyBuddy service and the controller of the account and Service data of all users of the Service (including the "operator" within the meaning of Russian Federal Law No. 152-FZ "On Personal Data"), whether they are located in the Russian Federation or elsewhere, and of visitors to the website https://replybuddy.io, including data submitted through lead and contact forms, which PRIME RADIANT LLC processes itself.
Sole Proprietor Nikolai Tolstov (INN 381205813752, OGRNIP 325385000012770) sells paid access to the Service in Russian rubles on his own behalf under an agreement with PRIME RADIANT LLC. For such purchases he is an independent controller (operator) of buyers' payment data, which he processes to accept payment, issue electronic fiscal receipts in accordance with Russian Federal Law No. 54-FZ, keep accounting records, and handle payment-related inquiries; this data is processed in the Russian Federation via the CloudPayments payment service. PRIME RADIANT LLC remains the controller (operator) of all other personal data described in this Privacy Policy (see "How We Disclose Personal Data").
We provide you with our website https://replybuddy.io as well as the services and offerings made available to you through this website ("Services"). When you use the Service or interact with us in any way (for example, by communicating via email), you may provide us with your personal data. This Privacy Policy explains how we handle and protect your personal data.
"Personal Data" means information that relates to, describes, or identifies you. This could include your name, date of birth, or email.
"You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
This Privacy Policy applies to your use of the Service. If you access or use the Service, you agree with and accept this Privacy Policy.
Information You Provide to Us
When you use or access the Service, create an account, send a message to us, or participate in activities on the Service, you may input personal data into the Service.
Profile and account information, such as full name, username and avatar, email address, telephone number, and billing plan status. Full payment card details are entered directly on the secure checkout page of the applicable payment provider (Lemon Squeezy or CloudPayments) and are neither collected nor stored on our servers.
Your or your client's personal information connected with third-party messaging and social media accounts (such as Telegram, Instagram, Avito, MAX, VK, and others) that you connect to the Service.
Other information that you enter, post, send, or submit to our Service (knowledge base articles, AI agent instructions, photos, videos, and files uploaded in conversations, hashed account credentials, OAuth tokens and API keys for connected channels, or information contained in communications that you send to us by email or other support channels).
Information Collected from Third Parties
We may receive information about you from other users, third-party services, public social media platforms, or public databases. For example, social media platforms may display your mailing address, email, or phone number.
Information Collected Automatically
Certain information is collected automatically when you use or visit our Service. This information does not reveal your identity (such as your name or contact information), but may include information about your device, its use, and other technical information. This information helps us maintain security, ensure optimization of the Service for your needs, and facilitate customer support.
We collect this information using server log files and the cookies and similar technologies described below.
Browser data: information that your browser automatically sends when you use the Service, including IP address, browser type, browser language, settings, and Service usage patterns.
Device data: information about the device you use, such as device type, model and manufacturer, device operating system brand and model, and operating system version.
Usage data: information about your use of the Service, including patterns, time, and date of your use of the Service.
Analytics data: general information about traffic and usage trends for the Service.
Cookies. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. For more information about cookies, and how to disable cookies, visit https://allaboutcookies.org/ .
Two types of cookies may be used within the provision of the Services – "session cookies" and "persistent cookies". Session cookies are temporary cookies that remain on your device until you leave the Services. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or "lifetime" of the specific cookie and your browser settings).
We use cookies and browser local storage needed for the Service to work (for example, to keep you signed in, remember your settings, and remember that you have seen the cookie notice), and we may use analytics tools to understand how the Service is used.
If you do not agree to our use of Cookies, you should set your browser settings accordingly or not use our Services. By continuing to use our Services without changing your settings, you are agreeing to our use of Cookies and the terms with regard to Cookies of this Privacy Policy.
Log files. Log files track actions occurring in the Services, and collect data including your IP address, browser type, Internet service provider, browser language, settings, and Service usage patterns, including referring/exit pages, and date/time stamps.
provide the Service to you, create and maintain your account, verify your identity, process transactions, and provide customer support;
improve the Service for you, identify activity patterns and usage trends;
communicate with you, send you emails, including confirmations and reminders, respond to your requests for assistance, or report on technical issues;
update you about changes to the Service, send messages about new features or promotions that may interest you;
maintain safety and security, detect, prevent, and respond to potential or actual security incidents, and protect against other illegal activities; or
other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
Disclosure of Personal Data to Third Parties
Public authorities and third parties when the law or a government order requires us to do so or when we need to protect our rights or users' rights, or prevent crime.
Our subsidiaries, affiliates, and co-owners. We may also disclose personal data to operators of the Service, subsequent owners, and their advisors in connection with a merger, reorganization, sale of our assets, or other change of control.
Service providers when they need access to your personal data to perform services for us, such as web hosting, data storage, user authentication, AI model providers, monitoring, payment processing, email, telephony, and customer service providers. The current list of our key service providers (sub-processors) and the places where data is processed is set out in Exhibit A (Section H) and Exhibit B of the Data Processing Agreement (https://replybuddy.io/dpa).
Sole Proprietor Nikolai Tolstov (INN 381205813752, OGRNIP 325385000012770), as an independent controller (operator), when you buy paid access to the Service in Russian rubles: the data necessary for the purchase is shared between him and PRIME RADIANT LLC so that he can accept the payment, issue the electronic fiscal receipt required by Russian Federal Law No. 54-FZ, keep accounting records, and handle payment-related inquiries, and so that PRIME RADIANT LLC can provide the purchased access to your account.
Advertisers, if general information can help them better understand our users. We do not share information that identifies who you are (such as name or email address). We may provide general information. This information allows us to optimize our advertising efforts, and advertisers are prohibited from using this information for any other purpose.
Other legal requirements
Comply with a legal obligation;
Protect and defend the rights or property of the Company;
Prevent or investigate possible wrongdoing in connection with the Service;
Protect the personal safety of users of the Service or the public;
Protect against legal liability.
Detailed Information on the Processing of Your Personal Data
The service providers we use may have access to your Personal Data. These third-party vendors collect, store, use, process and transfer information about your activity on our Service in accordance with their Privacy Policies. We advise you to review their Privacy Policy separately.
Disclosure of Anonymous Information
We may disclose anonymous information to any third party without notification. Anonymous information means information which does not allow the identification of an individual user, such as aggregated, anonymized, or de-identified information about the use of our services. Such information does not constitute personal data.
We have put in place security measures to protect your personal data from misuse, unauthorized access, disclosure, alteration, and destruction. We maintain appropriate administrative, technical, and physical safeguards. This includes password protection and other authentication controls. However, security on the internet can never be 100% guaranteed. We will take reasonable technical and organizational precautions to protect your personal data.
The right to know what data we have about you. To exercise this right, please contact us at support@replybuddy.io.
The right to correct, delete, or update your personal data. You can access and modify your personal data through your account or the settings section of the Service. If you need assistance, please contact us at support@replybuddy.io. Please note that sometimes we may not be able to modify or delete certain information. For example, we are required by law to keep certain information for a defined period.
The right to withdraw your consent to the processing of your personal data at any time by sending us a written notice at support@replybuddy.io. Please note that in some cases the law requires us to keep certain information for a defined period even after we receive a deletion request.
The right to opt out of receiving electronic marketing communications from us. We may periodically send you emails and messages promoting the use of the Service. You can opt out (unsubscribe) of receiving these messages by following the instructions included in each email or message. If you have any additional questions, please contact us at support@replybuddy.io.
This section of our privacy policy outlines how we comply with the General Data Protection Regulation ("GDPR") as it applies to individuals located in the European Union ("EU") and the European Economic Area ("EEA").
Data Controller
For the purposes of GDPR (and, as stated in the Introduction, for all other users of the Service), PRIME RADIANT LLC, a limited liability company registered in the Republic of Armenia (Reg. No. 286.110.1498160, TIN 02938343) with its registered office at 26a Movses Khorenatsi St, Office 210, Yerevan 0010, Republic of Armenia, is the data controller responsible for the processing of your personal data.
Legal Basis for Processing
Consent: Where you have given us explicit consent to process your personal data for specific purposes.
Contract: Where processing is necessary to fulfill a contract with you or to take steps at your request before entering into such a contract.
Legal Obligation: Where we are required to process personal data to comply with legal obligations imposed by the public authorities and third parties when the law or a government order requires us to do so or when we need to protect our rights or users' rights or prevent crime.
Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, provided that your fundamental rights and freedoms do not override those interests.
Data Transfers
As a company registered in the Republic of Armenia using service providers in multiple jurisdictions, your personal data may be transferred to, and processed in, countries outside your country of residence, including outside the EU/EEA. Our main application server and database are hosted in Lithuania (EU); our service providers process data in the United States, China, Japan, and other countries; Company personnel may access data from Armenia; and payments in Russian rubles are processed by CloudPayments in the Russian Federation. Details are set out in the Data Processing Agreement (https://replybuddy.io/dpa). We ensure that such transfers are compliant with GDPR requirements and take appropriate measures to safeguard your personal data. This may include implementing Standard Contractual Clauses or other appropriate safeguards.
Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws. Specific retention periods will depend on the nature of the data and the purpose of processing.
Your Rights
Right to Access: You may request access to the personal data we hold about you.
Right to Rectification: You may request that we correct or update inaccurate or incomplete data.
Right to Erasure: You may request that we delete your personal data under certain circumstances.
Right to Restriction: You may request that we restrict the processing of your personal data in certain situations.
Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
Right to Object: You may object to the processing of your personal data based on legitimate interests or direct marketing.
To exercise these rights, please contact us at support@replybuddy.io. Only you may make a verifiable consumer request related to your personal data. To verify your identity, we may ask you to verify the personal data we already have on file for you. We may ask you to provide your name, email address, and certain other pieces of identifying information.
Data Protection Contact
For inquiries or concerns regarding your personal data, contact us at support@replybuddy.io.
Our Service is intended only for persons aged 18 or older (see the Terms of Service) and is not directed to children or other minors. We do not knowingly collect personal data from anyone under the age of 18. If You are a parent or legal guardian and You are aware that Your child has provided Us with Personal Data, please contact Us at support@replybuddy.io. If We become aware that We have collected Personal Data from anyone under the age of 18, We take steps to remove that information from Our servers.
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
This Privacy Policy can be updated from time to time. Please check back periodically for the latest version of the Privacy Policy. If there are any significant changes made to the use of your personal data, we will notify you. Your use of the Service following any changes to this Privacy Policy constitutes your acceptance of any such changes.
This document is available in English and Russian. In the event of any discrepancy between the versions, the version in the language in which the user accepted the document prevails.
Limited liability company registered in the Republic of Armenia
Registration No.: 286.110.1498160 · TIN (ՀՎՀՀ): 02938343
Registered office: 26a Movses Khorenatsi St, Office 210
Yerevan 0010, Republic of Armenia
If you have any questions about this Privacy Policy, your privacy, or the protection of the personal data we hold about you, you can contact us at support@replybuddy.io.