1. General provisions

1.1 This Privacy Policy (hereinafter the "Policy") regulates the relations between the Limited Liability Company "Area Game" (OGRN 1201600071045, TIN 1659211213, 420064 Russia, Republic of Tatarstan, Kazan, Orenburgskiy trakt str. 160, room. 412), hereinafter referred to as AG LLC or "Operator", which is the right holder of the sites, services, games, programs and/or other products specified in paragraph 1.5 of this Policy (hereinafter referred to as the "Services", and individually as the "Service"), located, among other things, in the domain https://area-game.ru/ and its subdomains, as well as on other domains administered by AG LLC, and you, hereinafter referred to as the "User", regarding the processing of information about the User, including personal data, in the process of using the Services of AG LLC (hereinafter referred to as the "Information"), available through the client program, website, or by other means.

This Policy is available at: https://area-game.ru/page/privacy-policy.

1.2 Relationships related to the processing of Information, including but not limited to the collection, use, storage, distribution and protection of information about the Users of the Services, are governed by this Policy, privacy policies of individual Services and other rules posted within the Services of AG LLC (hereinafter collectively referred to as "Policies", and individually as "Policies"), as well as by the current legislation of the Russian Federation. Before using the Operator's Services, the User shall familiarize himself/herself with this Policy and all applicable rules.

1.3 Upon registration, each access and/or actual use of any of the Services, the User agrees to the terms of this Policy, privacy policies of individual Services, as well as the terms of agreements, provisions and rules of the Services used by him/her, which are posted on the pages (sections) of the respective Services, in the editions that were in effect at the time of actual use of such Services.

1.4 The rights and obligations of Users when processing their Information.

Users have the right to:

- get free access to information about yourself by viewing your User Account in the respective Service;

- using the tools of the Service to set the desired level of confidentiality (conditions of access to information) with respect to information about yourself, taking into account the functionality of the relevant Service (if applicable);

- independently make changes and corrections to the information about yourself by editing the information in the User Account, provided that such changes and corrections contain up-to-date and accurate information;

- delete information about yourself by editing information in the Account of the relevant Service (if applicable); in this case, the deletion of certain information about yourself by the User from the User Account in some Services may result in the inability to provide the User with access to these Services;

- require the Operator to clarify information about the User, block or destroy it if such information is incomplete, outdated, unreliable, unreasonably obtained or is not necessary for the stated purpose of processing and if the functionality of the Service does not allow the User to delete such information independently;

- on the basis of a request to receive information from the Operator regarding the processing of information about the User.

- to refuse to process personal data by submitting a request to the Operator in accordance with the procedure stipulated in Section 6 of this Policy.

1.5 The Operator's Services include:

- AG LLC's Internet Website, available at https://area-game.ru/;

- Interactive online computer game "Chronicle Online" (information available at https://area-game.ru/AsdaChroniclesFable).

 

2. Composition of Information

2.1 Information processed by the Operator shall include:

2.1.1 Credentials, which means:

- data about the User provided by the User to create an account in the process of registration in the Service: identifier in the Service (login), e-mail address, phone number;

- additional information to be filled in by the User when editing his/her account while using the Service.

- data additionally provided by the User at the Operator's request in order to fulfill the Operator's obligations to the User arising from the agreement on the provision of the respective Service, e.g. surname, name; date of birth; region of residence; date, time and place of registration/authorization on the Service; information about the Internet provider; information about the transactions made by the User while using the Service; e-mail address, telephone number.

2.1.2 Other data (non-personal data) necessary for the functioning of a particular Service, namely:

- data on technical means (devices), technological interaction with the Service (including IP address of the host, type of the User's operating system, browser type, geographical location, Internet service provider);

- information automatically received when accessing the Service using cookies;

- information obtained as a result of the User's actions in the Service, in particular, information about the addition of any content (if applicable);

- information obtained as a result of actions of other Users in the Service (if applicable);

- summarized analytical information on the use of Internet services.

2.2 By the functionality and rules of use of individual Services, the User may be given the opportunity to post any other information (if applicable) in the Services, in addition to the information specified in paragraph 2.1. of this Policy, if it does not contradict the requirements of the current legislation. The Operator has no purpose to process such information, as well as biometric and special categories of personal data. By posting information, the User understands that it may be available to an indefinite number of Internet users, taking into account the settings of the desired level of confidentiality.

2.3 If the functionality of the used Service allows to reflect information about the User in his/her Account, which is available for viewing by other Users of such Service or Internet users, the User agrees to reflect information about him/her in his/her Account. The User agrees that the Information, including Account and Other Data, as well as other information may be available to other Users of the relevant Service and/or other Internet users, subject to the existing functionality of the Service (as may be changed from time to time by the Operator).

2.4 The Operator does not verify the Credentials provided by the User and cannot judge whether they are accurate or whether the User has sufficient legal capacity to provide the Credentials. Nevertheless, the Operator assumes that the User provides true and sufficient Credentials and updates them in a timely manner. By registering in the respective Service or accessing it without registration, the User confirms that he/she has reached the legal age of use of such Service in accordance with the laws of the Russian Federation.

The Account and Other Data processed by the Operator to the extent necessary and sufficient for their classification as personal data in accordance with the applicable laws of the Russian Federation shall be processed by the Operator as personal data under the terms of this Policy and the privacy policies of individual Services.

2.5 Processing of cookies.

Cookies are small pieces of data that websites request from the browser used on the User's computer or mobile device. Cookies are stored locally on the Internet User's computer. The Operator collects and processes cookies in relation to Users visiting the Operator's Services.

The following types of cookies are used on the Services:

-Strictly necessary cookies / technical cookies: these cookies are necessary for the operation of the website and the provision of the Services to the User; among other things, they allow the Operator to identify the User's hardware and software, including the type of browser;

-statistical / analytical cookies: these cookies allow us to recognize users, count them and collect information such as the operations performed on the sites, including information about the web pages visited and the content that the User receives;

-technical cookies: these cookies collect information about how users interact with the site, which allows us to identify errors and test new features to improve the performance of the Services;

-Functional cookies: these cookies allow you to provide certain functions to make it easier to use websites, for example by storing preferences (such as language and location);

Cookies are processed by the Operator exclusively for the purpose specified in clause 3.2 of this Policy, under the conditions and in the manner specified in this Policy, in particular, based on the data obtained through cookies, the Operator develops the most useful functionality for the Services available to the User, conducts statistical studies, corrects errors in the Services and tests new features to improve the performance of the Services, personalizes them and displays the most relevant information for the User.

The information collected through cookies placed on the User's device may be transferred and made available to the Operator and/or third parties specified in paragraph 3.4 of this Policy, as well as companies that own web analytics services Yandex.Metrika, Google Analytics and/or other similar services.

The User may refuse to process cookies in the settings of his browser. In this case, the Operator's Service will use only those cookies that are strictly necessary for the operation of the Service and the provision of its functionality.

3. Conditions for processing Information

3.1 The Operator shall process Information about Users in accordance with the following principles:

- legitimacy of the purposes and methods of processing Information;

- the integrity of the Operator;

- compliance of the purposes of Information processing with the purposes predetermined and declared at the time of its collection, as well as with the Operator's powers;

- compliance of the volume and nature of the processed Information, methods of its processing with the purposes of Information processing;

- inadmissibility of combining databases containing User Information created for incompatible purposes.

3.2 Purposes of Information Processing

The Operator processes the Account Data and Other Data of the Service Users in order to fulfill the agreements concluded with the Users on the use of the respective Services, including for:

- authorization of Users in the respective Services;

- identification of Users in the respective Services;

- to restore Users' access to the respective Service, in case of loss of such access;

- management and administration of the Services;

- providing the User with personalized products and special functionality of the Services;

- communication with the User in order to provide technical support to the User;

- registration of applications for participation in alpha-, beta-, and open testing;

- informing Users about innovations and updates in the respective Services.

3.3 Information Gathering.

The User's Credentials are collected when the User registers with the respective Service by filling in the registration form, as well as in the future when the User edits the previously provided information or supplements his/her own initiative with the Credentials (if applicable) using the tools of the respective Service.

The Operator collects Other Data independently in the process of the User's use of the Service. In some cases, the collection of the User's Other Data starts from the moment the User accesses the Service (e.g., when downloading an Internet page or launching an application) until the User registers in the respective Service.

3.4 Processing and Transmission of Information.

The legal basis for the processing of User data when using the Services is:

- agreements concluded between the Users and the Operator on the use of the respective Service;

- federal laws, other regulatory legal acts in the field of personal data protection;

- Users' consent to the processing of their data.

The Operator processes the Users' credentials only if they are filled in by the User independently through special forms located in the respective Service, or provided by the User in order to fulfill the Operator's obligations to the User arising from the agreement on the provision of the respective Service. By filling in the relevant forms, the User expresses its consent to this Policy.

The user decides independently on the provision of their data and gives consent freely, of their own free will and in their own interest.

Account and Other Data of Users are not transferred to any third parties, except as expressly provided for in this Policy, the policies of individual Services, other applicable rules, and the laws of the Russian Federation.

The Operator may transfer Users' Account and Other Data to third parties, subject to the purpose specified in clause 3.2 of this Policy. Such third parties may include:

- third parties in respect of whom rights or obligations have been assigned or novated under the relevant agreement;

- any state or local government body to which the Operator is obliged to provide information in accordance with the applicable legislation upon the relevant request.

In order to provide high-quality, multifunctional, user-friendly and oriented to the personal needs and interests of Users of the Services, the Operator develops, improves, optimizes the current and introduces new functionality of the Services (of information, communication, educational, entertainment and other nature).

Taking into account the above, as well as taking into account the Operator's compliance with the processing purposes specified in clause 3.2 of this Policy, the User agrees and authorizes the Operator to perform the following actions:

- processing, including collection, recording, systematization, accumulation, storage, clarification (update, change), comparison, extraction, use, blocking, deletion/destruction of User's Account and Other Data.

In some cases, certain functionalities of the Services may be provided not by the Operator, but by third parties who act independently of the Operator and do not act on behalf of the Operator. In this case, Users are obliged to familiarize themselves with the rules of service provision and information/personal data protection policy of such third parties before using the relevant functionalities of the Services.

It is not allowed to extract and use Users' Account and Other Data, including for commercial purposes, without the Operator's permission.

3.5 Storage of Information

User Accounts and Other Data shall be stored in the Russian Federation, with storage exclusively on electronic media and processing using automated systems, except where non-automated processing of Accounts and Other Data is necessary in connection with the fulfillment of the requirements of the legislation of the Russian Federation.

Account and Other Data are stored until the purposes of their processing are achieved, unless otherwise stated in the privacy policy of the respective service.

3.6 Information Retention Periods

Account and Other Data shall be stored by the Operator during the term of validity of the agreement between the User and the Operator on the use of the respective Service, and after the termination of such agreement - during the period required and established by the current legislation of the Russian Federation.

3.7 Termination of Information processing

When the purposes of Information processing are achieved, the Operator shall stop processing of Account and Other Data in one of the ways provided for by the Federal Law "On Personal Data".

 

4. Measures to protect information

4.1 The Operator takes technical, organizational and legal measures to ensure protection of information about Users from illegal or accidental access to it, destruction, modification, blocking, copying, distribution, as well as from other illegal actions.

4.2 Technical security measures are implemented by the Operator taking into account the requirements of the RF legislation, the current state of the art, the nature of the processed information and the risks associated with its processing.

Information is processed predominantly automatically without access to it by the Operator's employees. If such access is granted to the Operator's employees, it is only to the extent necessary for such persons to perform their official duties, and such persons are obliged to comply with security requirements when accessing Information. In order to protect and ensure the confidentiality of data, all employees shall comply with internal rules and procedures regarding the processing of information. These persons also comply with all technical and organizational security measures provided for by the legislation of the Russian Federation and necessary for the protection of information about Users.

 

5. Limitation of Operator's liability

5.1 The Operator is not responsible for disclosure and distribution of information about the User by other Users of the Services or other Internet users in case such persons have access to the said information in accordance with the privacy level settings of the respective Service selected by the User, or in case of violation by the User of the safety of his/her login and/or password or other data necessary for authorization.

 

6. Appeals of Users

6.1 Information about the data processed by the Operator, including the User's personal data, in connection with the use of the respective Service shall be provided to the User or its representative upon application (request). 

6.2 Requests shall be sent in writing to the location address of the Operator or in any other form stipulated by the current legislation of the Russian Federation.

6.3 The User has the right to withdraw consent to the processing of his/her personal data by sending a written application to the Operator at the location of the Operator in accordance with the requirements of the current legislation.

 

7. Amendments and additions to this Policy

7.1 This Policy and the policies of individual Services may be changed by the Operator with notification of the User, including by posting a new edition of the amended Policy on the Website https://area-game.ru/page/privacy-policy. Changes to the Policy made by the Operator shall come into force on the day following the day of its posting on the Website of the new version of the Policy. The User undertakes to independently check this Policy and the Policies of individual Services for any changes made. Failure of the User to familiarize himself/herself with the Policy shall not serve as a basis for the User's failure to fulfill his/her obligations and for the User's failure to comply with the restrictions set forth in this Policy and the Policies of individual Services.

7.2 The User has the right to refuse to accept changes and amendments to this Policy and/or policies of individual Services, which means the User's refusal to use all and/or individual Services of AG LLC and all rights previously granted to him/her.

7.3 This Policy shall be governed by and interpreted in accordance with the laws of the Russian Federation. Issues not regulated by this Policy shall be resolved in accordance with the laws of the Russian Federation.

 

Operator: AG LLC.

Address: Republic of Tatarstan, Kazan, Orenburgskiy trakt str. 160, room. 412 

PRIMARY STATE REGISTRATION NUMBER (OGRN): 1201600071045

TAXPAYER IDENTIFICATION NUMBER (INN): 1659211213

TAX REGISTRATION REASON CODE (KPP): 165901001

Revision dated December 23, 2023