# Privacy Policy of the Game "Erudit"

## 1. About the service

**1.1.** The Game and its accompanying services are provided by Ilya A. Denisov, TIN 290210610742 (hereinafter "we", "us", "our").

**1.2.** This Privacy Policy supplements the End-User Licence Agreement available at [«Terms»](/eula/) and must be read together with it.

**1.3.** This Privacy Policy establishes how we collect and use your personal information when you (i) use the Game and the Website defined in the Terms, and (ii) use the mobile, online and downloadable products and services (hereinafter the "Services") offered by `erudit-game.ru` and its partners and affiliates on the Website, as well as the options available to you in connection with our use of your personal information (hereinafter the "Privacy Policy").

**1.4.** In the event of any conflict between this Privacy Policy and the Terms, this Privacy Policy prevails with respect to the processing of personal data.

## 2. About this Privacy Policy

**2.1.** In providing the Services, acting reasonably and in good faith, we assume that you:

- (a) have all the rights necessary to register on the Website and use the Services;
- (b) provide truthful information about yourself to the extent necessary to use the Services;
- (c) understand that, by publishing your personal information where the Services technically allow it and where it is available to other Users of the Services, you have expressly made that information public, and it may become available to other Users of the Website and to Internet users and be copied and distributed by them;
- (d) understand that certain types of information you transmit to other Users of the Service cannot be deleted by you or by us;
- (e) are aware of this Privacy Policy and accept it.

**2.2.** We do not verify the information you provide about Users, except where such verification is necessary for us to perform our obligations to you.

## 3. Information we collect about you

**3.1.** In order to give effect to the agreement between you and us and to provide you with access to the Services, we will improve, develop and introduce new features for our Services and expand the functionality of the available Services. To achieve these goals and in accordance with applicable law, we will collect, store, aggregate, systematise, extract, compare, use and supplement your data (hereinafter "processing"). We will also receive and transmit this data and the results of its automated analysis to our partners, as indicated in the table below and in section 4 of this Privacy Policy.

**3.2.** Below we describe in more detail the information we collect when you use our Services, why we collect and process it, and the legal grounds for doing so.

**3.3.** General provisions that apply to your use of the Website and the Services related to the online products of `erudit-game.ru` and its downloadable products, and those of its partners and affiliates.

We do not collect the data listed below by default. Some of it — in particular, an identity document and payment details — is processed **only if you voluntarily provide it**, as a rule when contacting Support or to confirm your identity. Other data (for example, technical device parameters) is processed automatically to the extent necessary for the Services to function.

| Information collected | Purpose | Legal basis |
|---|---|---|
| Data received from third parties, including social-network identifiers, app-store identifiers, your social-network nickname, email address and friends list, when you connect your social account (such as VK, Telegram, Apple Game Center and others) to our Services. | We import this information into your profile; use it to control and administer the Services and for certain social features (for example, to show which of your friends play the same game, or to let you publish your achievements to your social network); and to store data about your use of the Services (game progress and achievements) across different devices connected to the same social account. | Legitimate interests; performance of our contract with you. |
| Data you provide voluntarily, in particular when contacting Support or to confirm your identity: a copy of an identity document (first name, surname, photograph, document number), payment details and other data needed for verification. We request this only when necessary and do not collect it during ordinary use of the Game. | Identification, verification of your account and prevention of abuse or infringement of your rights or the rights of others (for example, to confirm your identity if you lose access to your account). | Legitimate interests; performance of our contract with you; processing necessary to comply with a legal obligation. |
| Information obtained from your behaviour while using the Services (including your in-game actions, achievements and badges). This information may be available to other users (for example, in leaderboards). | Control and administration of the Services; tailoring and improving the advertising offered to you and measuring its effectiveness. | Legitimate interests. |
| Information obtained from your use of the Services' payment features (for example, the first and last four digits of your bank-card number, needed to match a payment to your account). The full card number and other payment details are processed by the payment provider and are not stored by us. | Control and administration of the Services; investigating complaints on your behalf and improving service quality. | Legitimate interests; performance of our contract with you. |
| Information you create while using the Services (where the Services technically allow it), including information you publish in in-game chats. Depending on the Service and where it is placed, this information may be available to some or all other users. | Control and administration of the Services. | Legitimate interests (in particular, processing of data you have expressly made public); performance of our contract with you. |
| Information you create when submitting requests to our Support service. | Confirming your identity and fulfilling your request; investigating complaints and improving service quality. | Legitimate interests; performance of our contract with you. |
| Additional data obtained when you access the Services: technical details of your interaction with the Service, such as your IP address, time of registration, device identifiers, country and language settings, device model, operating system, browser type, Internet provider and/or telephone-network operator, network type and screen resolution. | Internal analysis to continuously improve the content of our Services and web pages, optimise your experience, understand errors, notify you of changes and personalise the Services; tailoring and measuring the effectiveness of advertising. | Legitimate interests; performance of our contract with you. |

**3.4.** Our legitimate interests include (1) maintaining and administering the Services; (2) providing you with the Services; (3) improving the content of the Services and web pages; (4) processing data you have expressly made public where it is available to other Users of the Services; (5) ensuring appropriate protection of your account; and (6) complying with any contractual, legal or regulatory obligations under any applicable law.

**3.5.** As part of servicing and administering the Services, we use this information to analyse user activity and to ensure that the rules and Terms of use of the Services are not violated.

**3.6.** Your personal information may also be processed where required by a law-enforcement or regulatory authority or institution, or to defend against or bring legal claims. We will not delete personal information where it is relevant to an investigation or dispute — it will be retained until those matters are fully resolved and/or for the period required and/or permitted under applicable/relevant law.

**3.7.** If you have given us consent to send you marketing information, you may withdraw your consent by changing the privacy settings of your account. The ability to unsubscribe will also be included in every email sent to you by us or our selected partners.

**3.8.** Please note that if you do not want us to process confidential and special categories of data about you (including data concerning your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life and/or sexual orientation), you should not post that information or transmit that data on the Website and/or in the Services. Once you provide this data, it will be available to other users of the Website, and it will be difficult for us to delete it.

**3.9.** Please note that if you withdraw your consent to the processing of data or do not provide the data we require to service and administer the Services, you will not be able to access the Services or register on the Website's web pages.

**3.10.** If we intend to process your data for any purposes other than those specified in this Privacy Policy, we will provide you with information about such additional purposes before we begin processing.

## 4. Data sharing

**4.1.** Publicly available data. Your username and other information you provide or post while using the Services may be available to all Users of the Services. By posting personal information in publicly available areas (resources available to other Users of the Services), you expressly make that information public, and it may become available to other Users of the Services and to Internet users and may be copied or distributed by them. Please note that from the moment other users have accessed or copied your data, neither you nor we can delete or withdraw such data from the possession of those other users.

**4.2.** Sharing with third parties. We may share your personal information with third parties only in the ways specified in this Privacy Policy. From time to time we may need to transfer your data to a third party in order to provide and operate the Services, to manage billing services, or to personalise, customise and improve our Services, and only in accordance with the purposes described in this Privacy Policy. We do not sell your personal information to third parties.

The transfer of personal data to recipients (regardless of their legal status) is carried out securely and in accordance with an agreement between us and each recipient, as may be required under applicable law. We undertake to ensure that each recipient is aware of the governing principles of personal-data protection and complies with them in accordance with the law and/or a specific contract.

**4.3.** Confidentiality obligations. Where we transfer your data to individual third parties, including third-party contractors and application developers, we always guarantee that such parties assume confidentiality obligations with respect to your personal data collected when you use the services or applications they offer. We will not transfer your personal data beyond the purposes specified in this Privacy Policy without your prior consent.

**4.4.** Advertising notice. Our advertising and recommendation management system is designed so that your information is not transferred directly to our third-party advertisers. An advertiser or recommendation creator may only choose to target advertising to groups of users falling under criteria such as age, gender, location (country, city) or others, or to target communities according to their type. If you fall into one of the target groups, you will receive advertising or a recommendation from such third-party partners or our affiliates. Nevertheless, such third-party advertisers or our affiliates may collect certain information about you if you interact in any way with the advertisements they provide.

**4.5.** Retargeting notice. An advertiser or recommendation creator may also upload a list of identifiers (for example, email addresses, telephone numbers) and identification data into our systems so that we (but not the consultant or recommendation creator) can check the match of users. They will see the number of matches, but not the matches themselves.

**4.6.** Disclosure to tax authorities. We reserve the right to disclose your personal information to the tax authorities where necessary in connection with your participation in public tournaments. We may also publish your data as part of tournament results lists on our Website and on third-party websites.

**4.7.** Disclosure in accordance with the law. We reserve the right to disclose your personal information in accordance with the requirements of the law, by court decision, or in special cases where we have grounds to believe that disclosure of such information is necessary to identify, contact or bring legal action against you or third parties, if you or such third parties violate the Terms, any other terms of service provided by us or our affiliates, or any applicable law, in order to protect our rights and interests. We also reserve the right to disclose your personal information if we believe in good faith that it is necessary to prevent fraud or other illegal actions.

## 5. Privacy settings

**5.1.** The Services may contain links to websites operated by third parties. We are not responsible for the privacy of your data when you access these links or interact with third-party services, and you should make sure you have read the relevant third party's privacy statement, which will govern your data-privacy rights.

**5.2.** We are not responsible for the actions of third parties who, as a result of your use of the Internet or the Services, gain access to your information in accordance with the level of privacy you have chosen.

**5.3.** We are not responsible for the consequences of using information that, by the nature of the Services, is available to any Internet user. We ask you to be responsible in your choice of information posted on the Website.

## 6. Transfer of information between countries

**6.1.** We may transfer and store some of your personal information on our servers or in databases outside the European Economic Area (EEA), including in Russia.

**6.2.** The countries to which we transfer your data may not have the same data-protection laws as those that exist in your jurisdiction. We take reasonable cybersecurity measures and/or apply standard contractual clauses to ensure appropriate protection of your data.

## 7. Retention periods

**7.1.** We will retain your personal information for as long as necessary to achieve the purposes for which the data was collected, depending on the legal basis on which the data was obtained, and/or on whether additional legal/regulatory obligations require the retention of your personal information for a period that is mandatory and/or permitted under applicable/relevant law.

**7.2.** You can delete your personal data by removing the data from your account; in addition, you can delete your account.

**7.3.** You can request the deletion of your account and data in our Services by contacting the Services' Support service (for details, see section 11).

**7.4.** We may delete your account or the information you publish in accordance with the Terms.

## 8. Your rights

**8.1.** In certain circumstances you have the following rights with respect to your personal information:

- (a) The right to access your personal information.
- (b) The right to rectification of your personal information: you may require us to update, block or delete your personal data if the data is incomplete, outdated, incorrect, unlawfully obtained or no longer relevant to the purpose of processing.
- (c) The right to restrict the use of your personal information.
- (d) The right to require that your personal information be erased if: its processing is no longer required in connection with the purposes for which it was collected or otherwise processed; you withdraw your consent where processing is based on consent; you reasonably object to the processing; such information has been processed unlawfully; or this is mandatory under the law.
- (e) The right to object to the processing of your personal information.
- (f) The right to data portability (in certain circumstances).
- (g) The right not to be subject to automated decision-making.
- (h) The right to lodge a complaint with a supervisory authority.
- (i) For processing based on your consent, the right to withdraw that consent at any time.
- (j) You may have other rights under the law of your country of residence, including the right to determine instructions concerning the processing of your personal data after your death.

**8.2.** You also have the right to delete personal information from your account yourself and to make changes and corrections to your information, provided that such changes and corrections contain up-to-date and accurate information. You may also review an overview of the information we hold about you. To exercise the rights provided for by data-protection law, you may contact the personal-data supervisory authority of your country of residence.

**8.3.** If you wish to exercise these rights, contact Support at the address indicated in section 11 of this Privacy Policy. We will try to respond to you within 30 days of receiving your request. We will need to confirm your identity before we can disclose any personal data to you.

## 9. Security measures

**9.1.** We take technical, organisational and legal measures, including, where possible, encryption, to protect your personal data from unauthorised or accidental access, deletion, alteration, blocking, copying and distribution.

**9.2.** Access to the Services is authorised using your login (email address or, where applicable, mobile telephone number) and password. You are responsible for keeping this information confidential. You must not share your credentials with third parties, and we recommend that you take measures to keep them confidential.

**9.3.** If you have forgotten your login details, you can ask us to send you an email (or, where applicable, an SMS) containing a recovery code.

**9.4.** To reduce the likelihood of unauthorised access by third parties, if you log in to your account from an unusual location or after several failed attempts to provide valid login details, we may block access to your account. After that, you will need to contact the Services' Support service and provide certain additional information to confirm your credentials and regain access to your account.

## 10. Changes to this Policy

**10.1.** At any appropriate time we may change and/or update this Privacy Policy. If this Privacy Policy changes, we will publish the updated version on this page. We will keep previous versions in our documentation archive. We recommend that you review this page regularly so that you are always aware of our information-handling practices and any changes to them.

## 11. Contact us

**11.1.** If you have any questions, please contact Support on Telegram: [@Erudit_GameBot](https://telegram.me/Erudit_GameBot), or send us your request in writing to: 236020, Kaliningrad, Pribrezhny district, Parkovaya St. 1, recipient — Ilya A. Denisov. Please refer to this Privacy Policy so that we can process your request effectively. We will try to respond to you within 30 days of receiving your request.

**11.2.** All correspondence we receive from you (written or electronic requests) is classified as restricted-access information and may not be disclosed without your written consent. Personal data and other information about you may not be used without your consent for any purpose other than responding to the request, except in cases expressly provided for by law.

**11.3.** The email address of our data-protection officer: [ilia.denissov@gmail.com].
