PERSONAL DATA PROCESSING POLICY FOR THE GAME “The Scrolls of Acronia. New hero.”

This Personal Data Processing Policy (hereinafter referred to as the “Policy”) defines the procedure for processing and protecting the personal data of users of the computer game “The Scrolls of Acronia. New hero.” (hereinafter referred to as the “Game”), carried out by the owner of the Game (hereinafter referred to as the “Owner”), and also establishes the rights of users regarding their personal data and the measures taken to ensure its security. This Policy applies to all individuals who use the Game and related services (hereinafter referred to as “Users”), whose personal data is processed by the Owner in connection with providing access to the Game, its functionality, and related services.

1. Terms and Definitions

For the purposes of this personal data processing policy, the following terms are used in the following meanings:

1.1. The Game — the video game “The Scrolls of Acronia. New hero.”, distributed via the Internet through platforms such as Google Play, RuStore and App Store, as well as through other distribution platforms, including software, the game world, the plot, characters, graphic materials, musical accompaniment, text materials, interface, game objects, updates, additions, fixes, as well as other elements and components that are part of the Game.
1.2. The right holder is the person specified in clause 13 of this agreement, who holds the exclusive rights to the Game and is the operator of the Users’ personal data.
1.3. User — an individual who installs, launches, or otherwise uses the Game and accepts the terms of the License Agreement and other mandatory documents of the Rightholder.
1.4. Account — a User’s account, created as needed to access certain functions of the Game and to identify the User.
1.5. Policy — this Personal Data Processing Policy, which regulates the procedure for processing and protecting Users’ personal data, and also defines Users’ rights and the Rightholder’s obligations regarding the processing of personal data.
1.6. The game’s website is the official website of the Rightholder, located on the Internet at the following address: https://leftforpain.com, and is intended for posting information about the Game, this Agreement, other legally significant documents, news, updates, as well as other information related to the Game and its use.
1.7. An update is any new version of the Game, bug fixes, changes to the game balance, additions of functional capabilities, the release of new game content, or any other change provided by the Rightholder.

2. General Provisions

2.1. This Personal Data Processing Policy defines the procedure for processing and protecting the personal data of Users of the Game “The Scrolls of Acronia. New hero.”, as well as the rights of Users regarding their personal data and the obligations of the Data Controller when processing personal data.
2.2. This Policy has been developed in accordance with the applicable legislation on personal data and defines the purposes, legal grounds, scope, methods, conditions and procedure for the processing of Users’ personal data, as well as the measures taken by the Rightholder to ensure the security of personal data.
2.3. The Rightholder is a personal data operator within the meaning of the applicable legislation and independently organizes and carries out the processing of Users’ personal data, defines the purposes of personal data processing, the composition of personal data subject to processing, as well as the actions (operations) performed with personal data.
2.4. This Policy applies to all Game Users whose personal data is processed by the Rightholder in connection with the use of the Game, the Game Website, and other services related to the Game.
2.5. This Policy applies to all personal data that the Rightholder receives directly from Users or automatically when using the Game, the Game Website, and other services related to the Game.
2.6. Using the Game means that the User has read and agreed to this Policy. In cases where obtaining the User’s consent to process personal data is required in accordance with applicable law, such consent is provided by the User in accordance with the established procedure.
2.7. This Policy is one of the mandatory documents regulating the use of the Game and is posted on the Game’s Website, providing the opportunity to familiarize oneself with it before using the Game.
2.8. In the event of a conflict between this Policy and the mandatory requirements of applicable personal data legislation, the provisions of such legislation shall apply.
2.9. Unless otherwise indicated by the content of this Policy, the terms used in this Policy have the meanings established by the End‑User License Agreement, and terms used in the singular include their use in the plural, and vice versa.

3. Composition of the processed personal data

3.1. When using the Game, the Rightholder processes the Users’ personal data necessary to provide access to the Game, ensure the operation of certain functions of the Game, identify the User, and interact with the User.
3.2. The personal data processed by the Rightholder includes:
• the User’s name;
• the User’s email address.
3.3. Personal data may be provided by the User independently when creating an Account, using certain functions of the Game, or when contacting the Rightholder regarding issues related to the use of the Game.
3.4. The Rightholder does not collect or process other categories of personal data, except in cases expressly provided for in this Policy or applicable law.
3.5. In the event of a change in the functionality of the Game and the need to process additional categories of personal data, the Right Holder has the right to make the corresponding changes to this Policy and publish its current version on the Game’s Website.
3.6. By downloading, installing, launching the Game, logging into the Game, and performing any other actions aimed at using the Game’s functional capabilities, the User confirms that they are familiar with the current version of this Policy posted on the Game’s Website, understand its provisions, and fully accept all its terms.
3.7. The User guarantees that the personal data provided by them is accurate, up‑to‑date, and belongs directly to the User or is provided by them on legal grounds.

4. Purpose of Personal Data Processing

4.1. The Rightholder processes Users’ personal data solely for purposes that comply with the requirements of applicable law and are necessary to enable the use of the Game.
4.2. The Rightholder processes Users’ personal data for the following purposes:
• to create, register and maintain the User’s Account;
• to identify the User when using the Game;
• providing the User with access to the Game, its functional capabilities, Updates, and other services related to the Game;
• ensuring the operation of the Game, eliminating technical errors and malfunctions, and improving the stability and security of its operation;
• reviewing Users’ appeals, requests, statements, and messages, as well as providing responses to them.
• sending notifications to the User related to the use of the Game, including messages about the operation of the Account, changes to the Game’s functionality, the release of Updates, changes to the terms of use of the Game and other legally significant documents;
• fulfilling the Obligor’s obligations provided for by applicable law;
• protecting the rights and legitimate interests of the Obligor and the Users, preventing the unlawful use of the Game, detecting, preventing and пресекая fraudulent activities, violations of the License Agreement, the Game Rules and other mandatory documents.
• conducting an analysis of the Game’s performance, preparing statistical and analytical information in an anonymized form, as well as improving the Game’s functionality and enhancing the quality of the services provided.
4.3. The Rights Holder does not process Users’ personal data for purposes incompatible with those specified in this Policy, unless otherwise provided for by applicable law or based on the User’s separate consent.

5. Legal grounds for processing personal data

5.1. The Data Controller processes the Users’ personal data on legitimate grounds and in accordance with the requirements of the legislation of the Russian Federation in the field of personal data.
5.2. The legal grounds for processing personal data are:
• the User’s consent to the processing of their personal data, provided in a form that allows confirming the fact of its receipt, if such consent is required in accordance with the legislation of the Russian Federation;
• the conclusion and execution of the License Agreement between the Rightholder and the User, including the provision of access to the Game, ensuring the operation of the Game’s functional capabilities, processing Users’ requests, and performing other actions related to the use of the Game.
• fulfilling the obligations established for the Rights Holder by the legislation of the Russian Federation, including the requirements of the legislation on personal data, consumer protection, tax law, and other applicable legislation;
• exercising the rights and legitimate interests of the Rights Holder related to the operation, development, and ensuring the security of the Game, preventing violations, ensuring the stable operation of the software product, protecting against fraudulent activities and abuse, provided that the rights and freedoms of the Users are respected.
5.3. In cases where the processing of personal data is carried out on the basis of the User’s consent, such consent is provided by the User by performing actions confirming their intention to provide personal data and allow its processing, including accepting the terms of this Policy and/or the License Agreement, as well as using the Game’s functional capabilities.
5.4. The User has the right to revoke the consent provided for the processing of personal data by sending a corresponding request to the Owner. At the same time, the withdrawal of consent does not affect the lawfulness of the processing of personal data carried out prior to such withdrawal, unless a different period is provided for by applicable law, this Policy, or is implied by the nature of the legal relationship between the Data Controller and the User.
5.5. In the event of the User’s withdrawal of consent, the Data Controller has the right to continue the processing of personal data if there are other lawful grounds provided for by the legislation of the Russian Federation.

6. Cross-border transfer of personal data

6.1. During the operation of the Game, the Right Holder may use third‑party services and technologies located both within the territory of the Russian Federation and outside the Russian Federation. In this regard, certain personal data of Users may be transferred and processed in foreign countries.
6.2. The Transboundary Transfer of Personal Data is carried out by the Rightholder only if there are lawful grounds and in accordance with the procedure established by the applicable legislation in the field of personal data protection.
6.3. When carrying out the Transboundary Transfer of Personal Data, the Rightholder takes the organizational and technical measures to protect personal data within the scope of its responsibility, as provided for by the applicable legislation, aimed at ensuring their security and preventing unlawful access, modification, dissemination, blocking, destruction, or other unlawful actions with personal data.
6.4. To ensure the operation of the Game, the Rightholder may use third‑party services, including analytical, technical, infrastructure, and other services (for example, services for analyzing the use of the Game, processing technical information, ensuring operational stability, and improving the quality of the services provided).
6.5. The list of third‑party services used may be changed by the Rightholder as the Game develops and is updated. Information about the current methods of processing personal data by such services may be contained in the documentation of the relevant service providers.
6.6. By using the Game, the User confirms that they are familiar with the provisions of this Policy and have been notified of the possibility of personal data being transferred to third parties, including persons located outside the territory of the Russian Federation, in cases provided for by this Policy and the legislation.

7. Methods and conditions of personal data processing

7.1. The data owner processes the Users’ personal data in compliance with the requirements of the applicable legislation and takes the necessary legal, organizational and technical measures to ensure the security of personal data and protect it from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as from other unlawful actions.
7.2. The processing of personal data is carried out both using automation tools and without using such tools, if this is necessary to achieve the purposes of processing personal data provided for in this Policy.
7.3. In the process of processing personal data, the Data Controller has the right to carry out the following actions (operations) with personal data:
• collection;
• recording;
• systematization;
• accumulation;
• storage.
• updating, modification;
• extraction;
• use;
• transfer, provision in cases provided for by this Policy and/or applicable law;
• de‑identification;
• blocking;
• deletion;
• destruction.
7.4. The processing of personal data is carried out for the period necessary to achieve the purposes of personal data processing, unless another period is provided for by applicable law or this Policy.
7.5. The Data Controller ensures the confidentiality of Users’ personal data and does not disclose it to third parties, except in cases provided for by this Policy, applicable law, or carried out with the User’s consent.
7.6. Access to personal data is granted only to persons who need such access to perform their duties, as well as to other persons in cases provided for by applicable law.
7.7. The Data Controller has the right to entrust the processing of personal data to third parties or to involve third parties in the processing of personal data in cases where this is necessary for the operation of the Game, for the performance of obligations to Users, or for compliance with the requirements of applicable law. At the same time, the Data Controller ensures that such persons comply with the requirements of the legislation on personal data and ensure the confidentiality and security of the processed personal data.
7.8. Upon achieving the purposes of personal data processing or when the need to achieve them ceases, as well as upon the occurrence of other grounds provided for by applicable law, personal data must be deleted or destroyed if their further storage is not required in accordance with applicable law.
7.9. If the User revokes consent to the processing of personal data, the Data Controller shall cease its processing and delete or destroy the personal data in accordance with the procedure and within the timeframes provided for by applicable law, unless there are other lawful grounds for continuing the processing of such data.
7.10. The right holder has the right to use anonymized personal data for statistical analysis, improving the functional capabilities of the Game, enhancing the quality of the Game’s operation, and for other purposes not related to identifying a specific User.

8. Transfer of personal data to third parties

8.1. The Data Owner ensures the confidentiality of Users’ personal data and does not transfer it to third parties, except in cases provided for in this Policy, applicable law, or carried out with the User’s consent.
8.2. The Data Owner has the right to transfer personal data to third parties in the amount necessary to achieve the purposes of processing personal data provided for in this Policy, including to the following categories of persons:
• service providers that ensure the operation of the Game, including authorization services, cloud data storage, analytics, technical support, message processing, and other services necessary for the Game to function;
• payment system operators and other entities that facilitate payments and refunds, if such functions are provided for in the Game;
• hosting providers, server infrastructure suppliers, and other entities that ensure the storage and processing of data necessary for the Game to function.
• to government bodies, local self‑government bodies, law enforcement agencies, courts, and other authorized bodies in the cases and in the manner provided for by applicable law.
8.3. When using the Game, Users’ personal data may be processed using third‑party services, including but not limited to:
• RuStore;
• App Store;
• Google Play Games;
• Google Analytics;
as well as other services whose use is necessary to ensure the operation of the Game or its individual functions
8.4. The Right Holder takes reasonable measures to ensure that third parties to whom personal data is transferred comply with the requirements of applicable personal data legislation and ensure the confidentiality and security of the personal data being processed.
8.5. The transfer of personal data to third parties is carried out exclusively to the extent necessary to achieve the purposes of processing personal data provided for in this Policy, unless otherwise provided for by applicable legislation.

9. Terms of personal data storage

9.1. The Data Controller shall store Users’ personal data no longer than is required to achieve the purposes of its processing, unless a different storage period is established by applicable law.
9.2. Users’ personal data shall be stored for the entire period of the User’s use of the Game and/or the existence of an Account, unless a longer storage period is required to fulfil the Data Controller’s obligations under applicable law.
9.3. In the event that the User’s Account is deleted or the use of the Game is terminated, personal data must be deleted or destroyed within a reasonable timeframe after the purposes of its processing have been achieved, unless its further storage is required in accordance with applicable law.
9.4. The Rightholder has the right to continue storing personal data after the User has terminated the use of the Game in cases where such storage is necessary to comply with the requirements of applicable law, to protect the rights and legitimate interests of the Rightholder, to consider claims, resolve disputes, or to fulfill other legal obligations.
9.5. Upon expiration of the storage period or upon achievement of the purposes for which personal data is processed, if there are no lawful grounds for its further storage, personal data must be deleted, destroyed, or de‑identified in accordance with the procedure established by applicable law.

10. User Rights when Processing Personal Data

10.1. The User has the right to receive information regarding the processing of their personal data, in the scope and in the manner provided for by applicable law.
10.2. The User has the right to request that the Data Controller clarify, update, or correct their personal data if such data are incomplete, inaccurate, or outdated.
10.3. The user has the right to request the deletion or destruction of their personal data in cases provided for by applicable law, if their further processing is not required to achieve the purposes of processing or there are no other lawful grounds for their processing.
10.4. The user has the right to revoke previously provided consent to the processing of personal data in cases where the processing is carried out on the basis of such consent. Withdrawal of consent does not affect the lawfulness of the processing of personal data carried out prior to the Правообладателем’s receipt of it, and also does not terminate the processing of personal data in cases where such processing is permitted without the User’s consent in accordance with applicable law.
10.5. The User has the right to request the restriction of the processing of their personal data in the cases and in the manner provided for by applicable law.
10.6. The User has the right to contact the Rightholder regarding issues related to the processing of their personal data, as well as to submit statements, requests, and demands concerning the exercise of their rights.
10.7. The User’s exercise of their rights must comply with the requirements of applicable legislation and must not infringe upon the rights and legitimate interests of the Rightholder, other Users, or third parties.

11. Processing of personal data of minors

11.1. The Game may be accessible to minors within the limits permitted by applicable law and the age restrictions established for the Game.
11.2. The Right Holder does not carry out targeted collection of personal data of minors without complying with the requirements of applicable law.
11.3. In cases where, in accordance with applicable law, the processing of personal data of a minor is permitted only with the consent of their parent, adoptive parent, guardian, or other legal representative, such consent must be obtained before the relevant processing of personal data begins.
11.4. If the Data Controller becomes aware that the personal data of a minor was obtained in violation of the requirements of applicable law, the Data Controller has the right to take measures provided for by law, including restricting the processing, deleting the personal data, or requesting the necessary consent of the legal representative.
11.5. The legal representatives of a minor User have the right to contact the Rightholder regarding the processing of the minor’s personal data, as well as to exercise the rights provided for by applicable law in relation to such personal data in the cases and in the manner established by law.
11.6. The Rightholder takes reasonable measures to ensure the protection of the personal data of minor Users on an equal footing with the personal data of other Users in accordance with this Policy and applicable law.

12. Final Provisions

12.1. This Policy comes into effect from the moment it is posted on the Game’s Website, unless another effective date is specified in the Policy itself, and remains in effect until it is replaced by a new version.
12.2. The Rightholder has the right to make changes and/or additions to this Policy at any time in order to bring it in line with changes in applicable legislation, the functional capabilities of the Game, the procedure for processing personal data, or for other reasons that the Rightholder deems necessary.
12.3. The Rightholder has the right to notify Users of changes to this Policy by posting the relevant information on the Game’s Website, in the Game, or by any other means that allows the information to be brought to the attention of Users.
12.4. Continued use of the Game after the new version of the Policy comes into force means that the User has read and accepts its terms, unless a different procedure for accepting changes is provided for by applicable law.
12.5. If any provision of this Policy is declared invalid, unlawful, or unenforceable, this shall not affect the validity and enforceability of the remaining provisions of the Policy.
12.6. For all issues related to the processing of personal data, the User has the right to contact the Copyright Holder using the contact details specified in this Policy or posted on the Game Website.
12.7. In all other matters not covered by this Policy, the Copyright Holder and the User shall be governed by the provisions of the applicable legislation.

13. Copyright Holder’s details

Information about the Copyright Holder, including the full name, OGRN, INN, location and contact details, is an integral part of this Agreement and is posted at: Copyright Holder

14. Date of last modification

Date of the last modification: August 30, 2026.