NEXT LVL Privacy Policy
Effective date: 19 October 2026.
1. Who we are
NEXT LVL is run by Alexey Grosman, an individual entrepreneur registered in Russia (OGRNIP 320253600063628, INN 250808746453, Moscow, Russian Federation). He is the controller of your personal data.
Contact for anything about your data: gros049494@yandex.ru, or message our bot @nextlvlsystembot.
This policy covers the NEXT LVL Telegram bot and mini app, the web app at app.nextlvlsystem.ru and the website nextlvlsystem.ru (together, the "Service").
We are based in Russia, so Russian data protection law (Federal Law No. 152-FZ "On Personal Data") applies to everything we do. If you live in the European Union or the United Kingdom, the GDPR or the UK GDPR may apply too. This policy is written to meet both.
2. The short version
- We keep what the game needs: your profile, goals, quests, journal and chats with the assistant.
- You can try NEXT LVL before signing in. Until you sign in, your choices stay in your browser.
- Steps and workouts are collected only if you connect them and tick a separate box. We never collect sleep, heart rate or weight.
- Your data is stored on a server in Russia. The AI assistant is powered by Claude from Anthropic (USA); it only receives what it needs to answer you, and only after you turn it on.
- We don't sell your data, share it with advertisers or show you ads.
- You can delete everything in one tap: Settings → "Delete account".
3. What we collect, why, and on what legal basis
| Purpose | Data | Legal basis (GDPR / UK GDPR) | How long |
|---|---|---|---|
| Trying the app before sign-in | Your chosen life area and whether you finished your first quest — kept in your browser only. We also count, anonymously, that someone started and finished a first quest (life area and campaign label only, no IP address, no identifiers) | Legitimate interest in understanding whether the first steps work (Art. 6(1)(f)); the anonymous count is not personal data | In your browser up to 30 days |
| Account and sign-in | Email address, or your Google account ID and name if you sign in with Google; Telegram ID, chat ID, name and username if you use Telegram; profile photo if you upload one | Performance of our contract with you (Art. 6(1)(b)) | While you have an account |
| Game, plan, reminders | Display name, gender, time zone, goals, habits, life areas, your answers about yourself, quests, progress, settings | Contract (Art. 6(1)(b)) | While you have an account |
| Journal | Entries, mood, energy, water, screen time, habit check-ins | Contract (Art. 6(1)(b)); if you write about your health, your explicit consent (Art. 9(2)(a)), given when you write it | While you have an account |
| AI assistant | Your messages, voice message transcripts, the assistant's replies | Contract (Art. 6(1)(b)); you turn the assistant on separately and can turn it off | 90 days |
| Steps and workouts | Daily steps and active minutes; workouts: type, duration, distance (from your phone or Strava). No sleep, heart rate, weight or routes | Your explicit consent (Art. 9(2)(a)), given when you connect | Until you disconnect |
| Calendars and task apps | From a calendar — busy time slots for today and the next 7 days, and if you turn on event titles — titles and times of events; from a task app — task (card) titles, due dates and whether they're done. We don't take descriptions, attendees, locations or attachments | Your consent when you connect (Art. 6(1)(a); terms) | While connected; events older than 14 days are deleted, everything is deleted when you disconnect |
| Alliance and squad | Name, class, rank, whether you closed your day, your Check-in answers, gestures, shared quests | Contract; these features are off until you turn them on | While you have an account or until you leave |
| Purchases (when we add them) | Payment ID, plan, amount, date | Contract; legal obligation to keep records (Art. 6(1)(b), (c)) | 5 years, including after account deletion |
| Early-access price reservation | Account ID, wave, reserved price, dates of reservation and cancellation | Steps you asked us to take before entering a contract (Art. 6(1)(b)) | Until the reserved price ends (12 months from your first payment); if you don't subscribe — 30 days after the activation period ends; deleted if you cancel the reservation |
| Improving the Service | Action codes in the app ("day closed", "app opened"), the campaign label you arrived with, answers to short surveys — never your journal text | Our legitimate interest in keeping the Service working and making it better (Art. 6(1)(f)); you can object at any time | While you have an account |
| Support | Your message, name, username or email | Legitimate interest in answering you (Art. 6(1)(f)) | 1 year |
| Website analytics | Cookies, Yandex Metrica data (IP address, browser, what you do on the page) | Your consent via the cookie banner (Art. 6(1)(a)) | Up to 1 year |
"Contract" means our Terms of Use.
You don't have to give us any of this, but without the account data and the data you enter we can't run the game for you. Steps, workouts, the AI assistant and the social features are optional.
Russian law requires a separate consent to process personal data. That's why sign-up includes a consent checkbox (nextlvlsystem.ru/en/consent). For EU and UK users this consent does not replace the legal bases above — it is an extra Russian-law formality.
Quests and tips are picked automatically from your goals and progress — see how recommendations work. We don't make decisions about you based solely on automated processing that have legal or similarly significant effects (Art. 22 GDPR).
4. The AI assistant
The NEXT LVL assistant is an AI system, not a person. Its replies are generated by Claude, a model made by Anthropic, PBC. They can be wrong and are not medical, psychological, legal or financial advice. Please don't rely on the assistant in an emergency — call your local emergency number instead (112 in the EU and UK, 911 in the US and Canada), or find a crisis line in your country at findahelpline.com.
Before your first message the app asks you to turn the assistant on. Until you do, the assistant gives built-in replies and nothing is sent to Anthropic. You can turn it off any time in Settings.
5. Where your data is stored
All data is stored on a server in the Russian Federation (Novosibirsk region), hosted by TIMEWEB.CLOUD LLC.
Russia has no adequacy decision from the European Commission or the UK government. That means Russian law does not offer the same level of protection as the GDPR, and Russian authorities can request access to data under Russian law. We protect your data with the measures in section 8 and only hand data over to authorities when the law requires it. You give your data to us directly when you use the Service.
The app also keeps a copy of your data on your device so it works faster and offline. It is wiped when you delete your account.
6. Who we share data with
Service providers in Russia (processing on our behalf):
- TIMEWEB.CLOUD LLC — hosting and storage;
- Tilda Publishing JSC — runs the website nextlvlsystem.ru (IP address and browser data);
- Yandex LLC — Yandex Metrica on the website, only if you click "Accept" on the cookie banner.
Sign-in providers (if you choose them):
- Google LLC (USA) — if you sign in with Google, Google confirms who you are and sends us your Google account ID and name. We don't ask Google for your email, and we don't keep your photo or anything else from your Google account. We never see your Google password;
- Telegram (Telegram Messenger Inc. and its group companies, UAE and British Virgin Islands) — if you use the bot or mini app. Telegram's own privacy policy applies to your Telegram account.
Outside Russia, if you turn on the AI assistant:
- Anthropic, PBC (USA) — generates the assistant's replies with its Claude model. It receives your message and the part of your profile and journal needed to answer, without your Telegram ID, username or email. Under its commercial terms Anthropic does not use this data to train its models;
- Cloudflare, Inc. (USA) — relays our requests to Anthropic and transcribes voice messages (the audio is not stored, only the text).
Outside Russia, delivery only (no storage on our behalf):
- Cloudflare, Inc. (USA) — if the website opens through our backup address (for example, from outside Russia), web app requests pass through it. Bot messages to Telegram pass through it too;
- your browser's notification service — Google LLC, Apple Inc., Mozilla Corporation or Microsoft Corporation (USA) — if you turn on notifications. The notification text is encrypted, so they can't read it.
If you connect them yourself:
- Strava, Inc. (USA) — we read your workouts (read-only) and tell Strava to disconnect when you disconnect;
- Apple Health or Health Connect — your phone sends us steps and workouts through your personal link. We send nothing to Apple or Google.
- Yandex LLC (Russia) — Yandex Calendar: Yandex will ask you to allow reading and changing your calendar — that's a Yandex limitation; we only read event times (and titles, if you turn them on) and never change anything in your calendar;
- calendar by link (iCal) — we download it from the server where it's stored, using your link (for example, Google LLC or Microsoft Corporation, USA, or Yandex LLC);
- Todoist Inc. (USA) — we read tasks and, if you turn it on, mark a task as done (off by default);
- Kaiten Software LLC (Russia) — Kaiten: we read cards you're responsible for (title and due date);
- calendars and task apps get nothing else from us. When you disconnect, we revoke our access where the service allows it. Event and task titles, times and durations are never sent to the AI assistant: it may only see the recommended load for your day, if you've allowed it to receive your data.
Other users: your ally and squad see what's listed in section 3, and only if you turned those features on. Your goals, journal, chats, steps and workouts are never visible to anyone else.
Authorities: only when the law requires it.
International transfers from us to Anthropic and Cloudflare in the USA are covered by their data processing terms, which include the European Commission's Standard Contractual Clauses (Art. 46 GDPR). You can ask us for more details at gros049494@yandex.ru.
7. Cookies and browser storage
| What | Set by | Why | How long |
|---|---|---|---|
| Tilda technical cookies | Tilda Publishing JSC | To make the site load and work | Up to 1 year |
nl_cookie_choice (browser storage) | Us | To remember your cookie choice | 1 year |
_ym_uid, _ym_d, _ym_isad and others | Yandex LLC (Metrica) | To see where visitors come from and how they use the site | Up to 1 year |
nl_s | Us | To keep you signed in to the web app and account page | 1 year, renewed on each visit; removed when you sign out |
nl_m | Us | To show the sign-in methods you used before first | 1 year |
nl_src | Us | The campaign label you arrived with (for example, "site" or an ad name). Saved to your account when you sign up | 30 days |
nl_guest (cookie and browser storage) | Us | Trying the app before sign-in: your chosen life area and whether you finished your first quest | 30 days |
nl_next, nl_fresh, nl_tgw | Us | To bring you back to the right page after signing in | 10–15 minutes |
nl_goal, nl_web, nl_consent_pending, nl_link_snooze, nl_push_dismiss, nl_cab_scan, nl_cab_seen, system_events_q (browser storage) | Us | Goal picked on the website, quick start of the web app, your consent until it reaches our server, "Later" on tips, what you've already seen on the account page, the app's event queue (sent only after you sign in) | Until you clear your browser; wiped when you delete your account |
Our own cookies and browser storage are needed for the site and web app to work, so they don't need your "Accept". Metrica only turns on after you click "Accept". You can change your mind any time with the "Cookie settings" link in the site footer, or block cookies in your browser.
8. How we protect your data
- All connections are encrypted (HTTPS/TLS).
- Only the controller has access to the server, by key.
- Step-sync links are stored as hashes. Strava access keys stay on the server.
- Access keys for calendars and task apps, and calendar links, are stored encrypted, only on our server.
- Profile photos are visible only to you. We shrink them and strip metadata, including location.
- Chats with the assistant are deleted automatically after 90 days.
- The assistant only gets what it needs to answer, without your Telegram ID, username or email.
- Daily backups are kept in Russia for no longer than 30 days. After you delete your account, your data disappears from backups within 30 days; if we ever restore a backup, we delete removed accounts from it again.
- When you delete your account we keep a record that the data was destroyed (without the data itself), as Russian law requires.
If a breach puts your data at risk, we will tell the authorities and, where required, you.
9. Your rights
Depending on where you live, you can:
- find out what data we hold about you and get a copy (access);
- get your data in a portable format;
- correct inaccurate data — most of it right in the app, including "What the System remembers";
- delete your data;
- restrict or object to processing, including processing based on our legitimate interests;
- withdraw any consent at any time (steps and workouts, the AI assistant, analytics cookies) — this doesn't affect processing that already happened, and the rest of the Service keeps working;
- complain to a data protection authority: in the EU, the authority in your country (list); in the UK, the ICO (ico.org.uk); in Russia, Roskomnadzor (rkn.gov.ru).
How:
- Delete everything: Settings → "Delete account". It's erased immediately. We only keep payment records (when we have them) because the law requires it. Messages the bot already sent you in Telegram stay in Telegram — you can delete them there.
- Any other request: email gros049494@yandex.ru or message @nextlvlsystembot. We reply within one month at the latest, usually much faster.
US residents. We don't sell or "share" your personal information (as those terms are defined in California and other US state privacy laws), we don't use it for targeted advertising, and we don't build profiles for advertising. You can use the rights above wherever you live.
10. Age
NEXT LVL is for people aged 16 and over. It is not directed at children, and we don't knowingly collect data from anyone under 16. If we learn that someone under 16 has an account, we delete it. If you think a child has signed up, email us. Paid features, when they appear, are for adults only.
11. Changes
We publish every new version at this address with its date. If we change the purposes or the data we collect, we'll tell you in the app and, where needed, ask for your consent again.