Privacy Policy
Operator: Individual entrepreneur (IP) Nikolai Nikolaevich Kostin,
INN 342601019130, OGRNIP 325470400026949, place of registration: Leningrad Region, town of Kudrovo.
Personal data requests: support@kngames.ru.
1. When processing begins
Processing begins when the Game is launched for the first time. The Game creates a game profile, stores the number of the current version of the documents and the time of the first launch, and shows a one-time hint: “By continuing to play, you accept the Agreement and the Policy (see ‘Settings’)”. This Policy and the User Agreement can be opened at any time in the Game: Settings → “Policy and terms”. Age, permission “to show ads” and permission for crash reports are not requested.
Profile, game and security data are processed in order to provide the features chosen by the user and to perform the User Agreement. The Game does not use Firebase or Crashlytics products or third-party product analytics. Ads are configured as non-personalized: without an advertising ID, geolocation, an advertising profile or the transmission of a personalization consent signal. If the purposes, the scope of the data or the recipients change materially, the Game will show a one-time hint about the new version.
2. Age
The Game does not request or store age or date of birth. It contains no content available only to adults. Age restrictions and purchase approval are applied by means of the App Store. A parent or other legal representative manages the child’s use of the Game where this is required by applicable law.
3. Data, purposes and legal bases
Categories of data subjects: users of the offline and online modes, owners of game profiles, buyers and authors of support requests.
| Data | Purpose | Legal basis |
|---|---|---|
| Internal profile ID, a random device “login/password” pair (technical identifiers not linked to the person’s identity), IP, platform, app and device version | Creating and protecting the online profile, authorizing requests, connection security | Performance of the User Agreement |
| Recovery code (stored in hashed form) | Transferring the profile to another device without signing in via third-party services | Performance of the Agreement; issued upon the user’s action |
| Version of the documents and time of the first launch, platform and app version | Confirming that up-to-date information has been shown | Fulfillment of the Operator’s obligations |
| Game actions, tables, moves and dice rolls, results, rating, coin balance, rewards, game logs | Running games, calculating progress, server-side verification of the legality of moves and protection against abuse, reviewing requests | Performance of the User Agreement |
| Chosen name and avatar from the built-in set | Public profile visible to other players; moderation | Performance of the Agreement |
| A photo the user chose on their device for the avatar (only a reduced square is sent to the server, without the shot's metadata) | Public profile visible to other players; moderation | Performance of the Agreement; voluntary action by the user after a warning that other players will see the photo |
| Product, transaction and entitlement status identifiers; no bank details | Delivering the purchase, restoring the entitlement, refunds and preventing double crediting | Performance of the contract and legal requirements |
| Depersonalized ad impression events (placement, result), without user identifiers | Configuring ad placements and monitoring ad failures | Acknowledgment of the first-launch hint |
| IP, app/OS version, device model, table number and technical events of the Game’s own server | Operation of the connection, security, prevention of abuse and fixing errors | Performance of the Agreement and fulfillment of the Operator’s obligations |
| IP, app/device data and impression events; no advertising ID and no geolocation | Showing and measuring non-personalized ads, protection against ad fraud | Providing the free version of the Game; consent or another applicable legal basis where required by the law of the user’s region |
Payment details are processed by the App Store; the Game’s server does not receive them. The Game does not request the phone number, contacts, geolocation or biometric data.
Processing operations: collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer to processors, provision of access to game participants, depersonalization, blocking, deletion and destruction. Other players are shown only the name, avatar, rating, statistics and the game information needed for a game.
4. Who receives the data
| Recipient / processor | Data and purpose | Geography |
|---|---|---|
| REG.RU | Profile, game data, game logs — hosting of the server, database and files | Russia |
| Apple (App Store) | Store and payment data — app distribution, payment and refunds | Cross-border processing under Apple’s rules is possible |
| RevenueCat | Internal client ID, product and transaction identifiers and entitlement statuses — verification, recording and restoration of purchases | Cross-border processing; the Customer profile is deleted when the account is deleted |
| Yandex Advertising Network and mediation partners: myTarget (VK LLC), Mintegral, Liftoff, BIGO Ads, Unity Ads, AppLovin, Google AdMob | IP, app/device data and impression events — non-personalized ads, measurement and fraud protection; no advertising ID and no geolocation | Yandex and myTarget — Russia (cross-border processing under Yandex’s rules is possible for Yandex); Mintegral, Liftoff, BIGO Ads, Unity Ads, AppLovin, Google AdMob — cross-border transfer (USA, Singapore, Hong Kong), depending on the partner selected by mediation |
The primary recording, systematization, accumulation and storage of the data of citizens of the Russian Federation are carried out in Russia. In the course of purchases, certain technical data may be transferred to RevenueCat and Apple, and in the course of ad requests — to the Yandex Advertising Network and its mediation partners. The specific scope of a transfer is limited to the data required by the respective function.
5. Retention periods
| Category | Period |
|---|---|
| Profile, progress, user content | While the profile exists; after deletion, active data is deleted or the necessary records are depersonalized within 30 days at the latest |
| Network access logs | Up to 30 days |
| Logs of games and of the technical operation of the Game’s own server | Up to 90 days, except for the investigation of a specific incident |
| Record of the documents’ version and the first launch | While the profile exists; deleted together with the account |
| Backups | Overwrite cycle of up to 30 days; deleted data is not returned to the production environment |
| Payment and accounting records | For the period required by law; the link to the game profile is removed when it is no longer needed |
6. Public information and moderation
The name, avatar, rating, statistics and the information needed for a game are visible to other participants. The internal ID, technical secrets and support requests are not shown publicly. Before a photo is chosen on the device, the Game warns that other players will see it. Uploading is optional; the photo stops being shown and its file is deleted when the user picks an avatar from the built-in set or deletes the account. Prohibited content can be reported; the Operator is entitled to hide it and restrict the profile.
7. Security
The Operator applies restriction of administrative access, hashing of secrets, backup and logging. Requests to the server are protected by TLS; payment notifications are verified on the server.
8. User rights and deletion
The user may request information, correction, restriction, withdrawal of consent or deletion by writing to support@kngames.ru. To locate the profile, state your in-game name and the substance of the request; do not send the recovery code, password or payment details. The Operator may request a secure confirmation sufficient to protect another person’s profile and responds within the time limits established by applicable law.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. Data necessary for the performance of the Agreement, the protection of rights or the fulfillment of legal obligations may be processed on another applicable legal basis to the extent necessary. The Operator’s actions or omissions may be appealed to Roskomnadzor or in court.
The account can be deleted within the Game (Settings → Delete account) or via the public page narde.kngames.ru/legal/app-store/delete-account.html. Active game data is deleted; the RevenueCat Customer profile is also deleted. Payment events are, where necessary, retained only after being unlinked from the account and after the public name/avatar has been removed. Deleting the game account does not cancel the subscription: it must be canceled in the App Store subscription settings. Restorable purchases can be linked to a new profile using the “Restore purchases” button; coin packs that have been spent are not restored.
9. Changes
In the event of a material change in the purposes, the scope of the data or the recipients, the Game will show a hint about the new version. The current version is permanently available at this address.