PRIVACY POLICY OF THE GAME "The Scrolls of Acronia. New hero.»

This Privacy Policy (hereinafter referred to as the "Privacy Policy") defines the procedure for ensuring the confidentiality of information received by the Copyright Holder when using the computer game "The Scrolls of Acronia. New hero." (hereinafter referred to as the "Game"), and also establishes principles for the use, storage, protection and transmission of such information in cases provided for by this Privacy Policy and applicable law. Using the Game, including downloading, installing, launching, creating an Account, making in-game purchases, using certain Game features, or performing any other actions related to using the Game, means that the User has read this Privacy Policy, understands its content, and agrees to its terms in full.

1. Terms and Definitions

For the purposes of this Privacy Policy, the following terms are used in the following meaning:
1.1. The video game "The Scrolls of Acronia. New hero.", distributed via the Internet through platforms such as Google Play, RuStore and the App Store, as well as through other distribution platforms, including software, game world, plot, characters, graphics, music, text materials, interface, game objects, updates, additions, fixes, as well as other elements and components included in the Game.
1.2. The Copyright Holder is the person specified in clause 13 of this agreement, who has the exclusive rights to the Game and grants the User the right to use it under the terms of this Agreement.
1.3. The User is an individual who installs, launches or otherwise uses the Game and accepts the terms of this Agreement.
1.4. Device — a mobile device, personal computer, laptop or other compatible device that meets the minimum system requirements of the Game and is used by the User to launch and use it.
1.5. Gameplay is a set of User actions performed in the Game, including exploring the game world, completing tasks, participating in battles, developing a character, creating items through the crafting system, interacting with other Users through Game chat and using other game features.
1.6. Account — a User account created, if necessary, to access certain functions of the Game and identify the User.
1.7. Game content — any objects, materials and elements of the Game, including characters, objects, weapons, armor, game locations, tasks, images, animations, musical compositions, sound effects, texts and other results of intellectual activity included in the Game.
1.8. Digital objects — in-game currency, game items, equipment, weapons, armor, consumables, resources, characters, pets, skills, abilities, achievements, awards, cosmetic items, game sets, subscriptions, additional functionality, virtual services, as well as any other digital objects, usage rights or elements Games provided to the User during the use of the Game, regardless of the method of obtaining them.
1.9. Game name – the in-game User name that the User creates for himself when creating an Account.
1.10. User Content — any materials created or posted by the User in the Game, including, but not limited to, messages in the Game Chat, avatars, profile photos, Game names and other data, if the corresponding functions are provided by the Game
1.11. Game chat is a text messaging function built into the Game between Users designed for communication, interaction and coordination of actions during the use of the Game.
1.12. Update — any new version of the Game, bug fixes, game balance changes, additional functionality, release of new game content, or other changes provided by the Copyright Holder.
1.13. Privacy Policy is a document that defines the procedure for ensuring the confidentiality of information received by the Copyright Holder when using the Game, the principles of its use, storage, protection and transmission, as well as informing Users about the measures taken by the Copyright Holder to ensure the security of such information in accordance with applicable law.
1.14. The Parties are the Copyright Holder and the User, collectively referred to as the Parties, and separately as the Party.
1.15. The game's website is the official website of the Copyright Holder, located on the Internet at: https://leftforpain.com , intended for posting information about the Game, this Agreement, other legally relevant documents, news, updates, as well as other information related to the Game and its use.
1.16. The rules of the game are one of the required documents located on the Game's Website for the right to use the Game.
Unless otherwise indicated in the content of this Agreement, terms used in the singular include their use in the plural, and vice versa.

2. General provisions

2.1. This Privacy Policy defines the principles of ensuring the confidentiality of information received by the Copyright Holder when using the Game, as well as the procedure for using, storing, protecting and transmitting such information in cases provided for by this Privacy Policy and applicable law.
2.2. This Privacy Policy is mandatory for all Users using the Game, regardless of the method of obtaining it, installation or use.
2.3. This Privacy Policy is one of the mandatory documents of the Copyright Holder governing the use of the Game, and is applied in conjunction with the End User License Agreement, Personal Data Processing Policy, Game Rules, Refund Rules, and other documents of the Copyright Holder on the Game's Website.
2.4. This Privacy Policy has been developed in accordance with the applicable legislation of the Russian Federation and is applied to the extent that it does not contradict the mandatory requirements of the legislation of the state in which the User uses the Game.
2.5. The provisions of this Privacy Policy apply to information received by the Copyright Holder when downloading, installing, launching, using the Game, creating and using an Account, making in-game purchases, contacting customer support, visiting the Game's Website, as well as when using other Game functionality.
2.6. The processing of Users' personal data is carried out in accordance with the Personal Data Processing Policy. This Privacy Policy does not replace the Personal Data Processing Policy and is applied in conjunction with it.
2.7. Unless otherwise indicated in the content of this Privacy Policy, the terms used in this document have the meanings established by the End User License Agreement, and the terms used in the singular include their use in the plural, and vice versa.

3. Information collected when using the Game

3.1. When using the Game, the Copyright Holder may receive the information necessary to ensure the functioning of the Game, provide the User with access to its functionality, improve the quality of the Game, ensure security, and comply with the requirements of applicable law.
3.2. Depending on the functionality of the Game used by the User, the Copyright Holder may receive the following categories of information::
• information provided by the User when creating and using an Account;
• Game name;
• data required to identify the User in the Game;
• information about the User's actions in the Game, game progress, achievements, game settings and the use of Game functionality;
• User-generated content, if the corresponding functions are provided by the Game;
• messages sent by the User via the Game Chat, if necessary to ensure security, review requests, comply with legal requirements or comply with the Rules of the Game.;
• information contained in the User's requests to the support service.
3.3. When using the Game, the Copyright Holder can also automatically receive technical information, including:
• IP address;
• Device Information;
• information about the operating system and its version;
• information about the Game version;
• Language settings;
• Device identifiers and other technical identifiers, if their receipt is provided by the functionality of the Game or the distribution platform used.;
• information about the launch and usage time of the Game;
• information about crashes, errors, performance, and stability of the Game;
• event logs (logs) necessary to ensure the performance and security of the Game.
3.4. When making in-game purchases, the Copyright Holder may receive information about the fact of the payment, its amount, date, time, transaction status, transaction identifier, and other information provided by the Distribution Platform, Payment System, or other persons involved in payment processing. At the same time, the Copyright Holder does not receive information about the full bank card number, CVC/CVV code, PIN code and other payment details, which are processed by the relevant Distribution Platform, Payment System or credit institution.
3.5. When using the Game, third-party analytics services, advertising services, cloud services, fault handling services and other technological solutions may be used that can automatically receive technical information to the extent necessary for their operation, in accordance with their rules and privacy policies.
3.6. The Copyright Holder does not collect information to the extent necessary to achieve the goals related to the use of the Game, unless otherwise provided by applicable law or required to provide certain functionality of the Game.

4. Purposes of using information

4.1. The information received by the Copyright Holder when using the Game is used exclusively for purposes consistent with this Privacy Policy, the Personal Data Processing Policy, the License Agreement, the Rules of the Game, the Rules for Refunding Funds and applicable legislation.
4.2. The Copyright Holder has the right to use the information received for the following purposes:
• providing the User with access to the Game and its functionality;
• Account creation, maintenance, and use;
• saving game progress, achievements, settings and other data related to the use of the Game;
• providing the User with purchased Digital Objects, additional functionality and other Game elements;
• ensuring stable and safe operation of the Game;
• identification, prevention and suppression of violations of the License Agreement, the Rules of the Game and other documents of the Copyright Holder;
• preventing fraudulent actions, unauthorized access to Accounts, and other actions that may harm the Copyright Holder, Users, or third parties;
• processing User requests and providing technical support;
• analyzing the operation of the Game, identifying errors, failures and other technical problems, as well as their elimination;
• improving the gameplay, Game functionality, and improving the quality of services provided;
• conducting statistical analysis and preparation of anonymized analytical information;
• compliance with the requirements of applicable legislation, judicial acts and legal requirements of authorized state bodies.
4.3. The Copyright Holder has the right to use anonymized information to analyze the use of the Game, evaluate the effectiveness of individual functionality, develop new game mechanics, improve the quality of the Game, conduct statistical research and other purposes not related to the identification of a particular User.
4.4. The information received is not used by the Copyright Holder for purposes incompatible with the purposes of obtaining it, except in cases expressly provided for by applicable law or with the consent of the User, if obtaining such consent is mandatory.
4.5. The Copyright Holder shall take reasonable organizational and technical measures aimed at ensuring the confidentiality of information, preventing unauthorized access to it, its misuse, modification, disclosure, destruction or other unlawful actions.

5. Information storage

5.1. The Copyright Holder stores the information obtained during the use of the Game for no longer than is necessary to achieve the goals provided for in this Privacy Policy, the Personal Data Processing Policy, the License Agreement, the Rules of the Game, the Rules for the Refund of Funds and applicable law.
5.2. The storage period of information is determined depending on the nature of such information, the purposes for obtaining it, the requirements of applicable law, the need to ensure the functioning of the Game, the protection of the rights and legitimate interests of the Copyright Holder and Users, as well as the fulfillment of obligations arising from the use of the Game.
5.3. Upon achieving the purposes of processing and storing information, or if there is no need for its further storage, the Copyright Holder shall take reasonable measures to delete, destroy, depersonalize or terminate its use, unless otherwise provided by applicable law.
5.4. Information may be stored longer than the periods specified in this Privacy Policy if such storage is necessary to comply with the requirements of applicable law, to comply with judicial acts that have entered into force, to consider User appeals and claims, to resolve disputes, to protect the rights and legitimate interests of the Copyright Holder, or to fulfill other obligations provided for by law.
5.5. The processing and storage of personal data of Users who are citizens of the Russian Federation is carried out using databases located on the territory of the Russian Federation. In cases where cross-border transfer of personal data of such Users is carried out during the use of the Game, such transfer is carried out only after ensuring their initial recording and storage on the territory of the Russian Federation and in accordance with the requirements of applicable legislation.
5.6. After the User stops using the Game, certain information may continue to be stored for the period necessary to fulfill the obligations of the Copyright Holder, ensure information security, prevent fraud, maintain accounting and tax records, as well as in other cases provided for by applicable law.
5.7. Information is stored in compliance with confidentiality requirements and protective measures provided for by this Policy. Privacy Policy, Personal Data Processing Policy and applicable laws.

6. Ensuring the confidentiality of information

6.1. The Copyright Holder shall take the necessary organizational and technical measures aimed at ensuring the confidentiality of information obtained while using the Game, as well as preventing its unauthorized or accidental access, modification, distribution, provision, destruction, blocking, copying, deletion and other illegal actions.
6.2. Access to information is provided only to those employees, representatives, contractors and other persons who need such access to perform their duties or provide services to the Copyright Holder, provided they comply with confidentiality requirements and applicable laws.
6.3. The Copyright Holder does not disclose confidential User information to third parties, except as provided for in this Privacy Policy, the Personal Data Processing Policy, the License Agreement, applicable law, or with the User's consent, if obtaining such consent is mandatory.
6.4. The Copyright holder has the right to disclose information if such disclosure is necessary.:
• to comply with the requirements of applicable law;
• for the execution of a judicial act that has entered into legal force;
• at the legitimate request of authorized state bodies;
• to protect the rights, legitimate interests, or safety of the Copyright Holder, Users, or third parties;
• to prevent, identify, investigate and suppress illegal actions, fraud, violations of the License Agreement, Game Rules or other documents of the Copyright Holder.
6.5. The copyright holder takes reasonable measures to ensure the safety of information, but cannot guarantee the absolute protection of information from all possible threats related to the use of information and telecommunication networks, software, equipment or actions of third parties.
6.6. The User is also obliged to take reasonable measures to ensure the confidentiality of information related to the use of the Game, including ensuring the safety of data necessary to access the Account and preventing their transfer to third parties.
6.7. In case of detection of unauthorized access to information or circumstances that may affect its confidentiality, the Copyright Holder has the right to take the necessary measures aimed at eliminating the consequences of such circumstances, protecting information and ensuring the safety of the Game.
6.8. The provisions of this section apply to the extent that they do not contradict the mandatory requirements of the applicable legislation and do not restrict the User's rights granted by such legislation.

7. Protection of minors' information

7.1. The Copyright Holder pays special attention to ensuring the confidentiality of information of underage Users and takes reasonable measures aimed at complying with the requirements of applicable legislation when using the Game by such Users.
7.2. The use of the Game by minors is allowed in the cases and in the manner prescribed by applicable law. In cases where, in accordance with the law, the consent of a parent, adoptive parent, guardian or other legal representative is required, such consent must be obtained before using the Game or performing other actions for which consent is mandatory.
7.3. The Copyright Holder does not purposefully collect information about minors in cases where such collection is prohibited by applicable law.
7.4. If the Copyright Holder becomes aware that the information of a minor has been obtained in violation of the requirements of applicable law, the Copyright Holder has the right to take the necessary measures to stop processing such information, delete it, or restrict access to it, unless otherwise provided by law.
7.5. Parents, adoptive parents, guardians or other legal representatives of a minor have the right to contact the Copyright Holder on issues related to the use of the Game by a minor, as well as in cases provided for by applicable law, with requirements for clarification, restriction of processing or deletion of information.
7.6. This section applies to the extent that its provisions do not contradict the mandatory requirements of applicable law and do not restrict the rights of underage Users and their legal representatives granted by such legislation.

8. Using third-party services

8.1. In order to ensure the functioning of the Game, provide individual functionality, process in-game purchases, analyze the operation of the Game, advertise, and increase the stability and security of the Game, the Copyright Holder has the right to use third-party services, software solutions, and information systems.
8.2. When using the Game, the following may be used, including:
• Distribution platforms;
• Payment systems;
• analytics services;
• advertising services;
• Error and crash handling services;
• cloud services;
• other technological solutions necessary for the functioning of the Game.
8.3. The number of third-party services used may include, but not limited to:
• Google Play;
• App Store;
• RuStore;
• Google Play Games;
• Google Analytics;
• Firebase;
• Yukassa;
• Yandex services;
• other similar services used by the Copyright Holder.
8.4. Individual third-party services may independently collect, process, store and protect information in accordance with their own rules, privacy policies, user agreements and other documents. The copyright holder does not determine how information is processed by such services and is not responsible for their activities, except in cases provided for by applicable law.
8.5. When using third-party services, information may be shared with relevant persons to the extent necessary to provide the User with access to the Game's functionality, processing in-game purchases, ensuring security, conducting analytics, troubleshooting technical problems and achieving other goals provided for in this Privacy Policy and the Personal Data Processing Policy.
8.6. The Copyright Holder recommends that Users familiarize themselves with the privacy policies, user agreements, and other documents of third-party services used in the Game.
8.7. The use of third-party services is carried out in accordance with the requirements of applicable law, as well as the terms and conditions of the relevant services.

9. Transfer of information to third parties

9.1. The Copyright Holder ensures the confidentiality of information obtained when using the Game and does not transfer it to third parties, except as provided for in this Privacy Policy, the Personal Data Processing Policy, the License Agreement, applicable law, or with the consent of the User, if obtaining such consent is mandatory.
9.2. The Copyright holder has the right to transfer information to third parties to the extent necessary for:
• ensuring the functioning of the Game and its individual functionality;
• providing the User with access to the services used during the operation of the Game;
• handling in-game purchases and refunds;
• providing technical support to Users;
• ensuring the information security of the Game;
• compliance with the requirements of the applicable legislation.
9.3. The transfer of information may be carried out, in particular:
• Distribution platforms;
• Payment systems;
• Cloud infrastructure providers;
• analytics services;
• advertising services;
• contractors and other persons engaged by the Copyright Holder to ensure the operation of the Game;
• state bodies, local self—government bodies, courts and other authorized bodies - in cases and in accordance with the procedure provided for by applicable law.
9.4. The Copyright Holder shall take reasonable measures to ensure that the persons to whom information is transmitted in accordance with this Privacy Policy ensure its protection and confidentiality within the limits provided for by the agreements concluded with them and the applicable by legislation.
9.5. If cross-border information transfer is carried out when using the Game, such transfer is carried out in compliance with the requirements of applicable legislation and only to the extent necessary to ensure the operation of the Game, the use of Distribution Platforms, Payment systems, analytics services, cloud services and other technological solutions.
9.6. The Copyright Holder does not sell, exchange or otherwise provide confidential User information to third parties, unless otherwise is expressly provided for by applicable law or is carried out with the User's consent in cases where obtaining such consent is mandatory.
9.7. The transfer of personal data of Users is carried out in accordance with the procedure and conditions established by the Personal Data Processing Policy.

10. User Rights

10.1. The User has the right to receive information about the procedure for ensuring the confidentiality of information when using the Game in accordance with this Privacy Policy, the Personal Data Processing Policy and applicable legislation.
10.2. The User has the right to contact the Copyright Holder on issues related to ensuring the confidentiality of information, using the Game, as well as exercising their rights provided for in this Privacy Policy and applicable law.
10.3. The User has the right to request clarification, updating, restriction of use or deletion of information in cases and in accordance with the procedure provided for by the Personal Data Processing Policy and applicable legislation.
10.4. The User has the right to refuse to use certain functionality of the Game if their use involves the provision of certain information, provided that such refusal does not make it impossible to use the relevant functions of the Game.
10.5. The User has the right to stop using the Game at any time. However, certain information may continue to be stored by the Copyright Holder in cases provided for by applicable law, the Personal Data Processing Policy, or other documents of the Copyright Holder.
10.6. The User has the right at any time to request the deletion of his Account, as well as related personal data and other information. The Account is deleted through the Game's Website in the User's personal account. The data deletion request is processed by the Copyright Holder within a period not exceeding 60 (sixty) calendar days from the date of its receipt. After deleting an Account, game progress, Digital Objects and other related data are permanently destroyed and cannot be restored, with the exception of information that the Copyright Holder is responsible for storing in accordance with applicable law.
10.7. The User has the right to receive clarifications on issues related to the application of this Privacy Policy by sending an appropriate request to the Copyright Holder at the email address indicated on the Game's Website or in the Copyright Holder's details.
10.8. The User exercises the rights provided for in this section in accordance with the procedure established by the Personal Data Processing Policy, the License Agreement and the applicable legislation of the Russian Federation.

11. Changing the Privacy Policy

11.1. The Copyright Holder has the right to make changes and/or additions to this Privacy Policy at any time at its discretion without prior agreement with the Users.
11.2. Changes and/or additions to this Privacy Policy may be made in order to bring its provisions in line with applicable law, to change the functionality of the Game, the technologies used, Distribution Platforms, Payment Systems, third-party services, as well as for other reasons that the Copyright Holder deems necessary.
11.3. The new version of this Privacy Policy comes into force from the moment it is posted on the Game's Website, unless another effective date is provided for by the new version of this Privacy Policy.
11.4. The Copyright Holder has the right to notify Users of changes to this Privacy Policy by posting relevant information on the Game's Website, in the Game, or in any other way that allows such information to be brought to the attention of Users.
11.5. The User undertakes to independently monitor changes to this Privacy Policy and regularly review its current version.
11.6. Continued use of the Game after the entry into force of the new version of this Privacy Policy means that the User has read its terms and accepts them in full, unless otherwise provided for by applicable law.
11.7. If the User does not agree with the new version of this Privacy Policy, he has the right to stop using the Game and delete it from his Device, unless otherwise provided by the License Agreement and applicable law.

12. Final provisions

12.1. This Privacy Policy comes into force from the moment it is posted on the Game's Website, unless another effective date is specified in the Privacy Policy itself, and is valid until it is replaced by a new version.
12.2. If any provision of this Privacy Policy is found to be invalid, illegal, or unenforceable in whole or in part, this does not invalidate the remaining provisions of this Privacy Policy, which remain legally binding.
12.3. In everything that is not regulated by this Privacy Policy, the Copyright Holder and the User are guided by the End User License Agreement, the Personal Data Processing Policy, the Rules of the Game, the Rules for Refunding Funds, other documents of the Copyright Holder governing the use of the Game, as well as the applicable legislation.
12.4. In the event of a conflict between this Privacy Policy and the Personal Data Processing Policy regarding the processing of personal data, the provisions of the Personal Data Processing Policy shall prevail.
12.5. All disputes arising in connection with the application of this Privacy Policy are resolved through negotiations between the Copyright Holder and the User, and if an agreement is not reached, in accordance with the procedure established by applicable law.
12.6. For questions related to the application of this Privacy Policy, the User has the right to contact the Copyright Holder at the email address indicated on the Game's Website and/or in the details of the Copyright Holder.
12.7. This Privacy Policy is written in Russian. In case of translation of this Privacy Policy into other languages, the text in Russian takes precedence, unless otherwise provided by applicable law.

13. Details of the Copyright Holder

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. Last modified date

Date of the last modification: August 30, 2026.