Privacy Policy

This document (hereinafter referred to as the Policy) is made to inform natural persons specified herein on actions carried out with their personal data by Ltd (hereinafter referred to as Company).

Scope of the Policy

  • Company is a provider of interactive Internet entertainment service (hereinafter referred to as the Services)
  • The Policy describes terms and conditions of data processing as to natural persons, which processing relates to any potential, existing, and former clients of a Company who are natural persons and interested in, do or did use the Services of Company (hereinafter referred to as the Users or you)
  • The Policy provides information on how Company processes your personal data in connection with the offered Company Services, using its internal resources and website (hereinafter referred to as the Website)
  • The Policy operates along with other terms and conditions of the use of the Services and Website
  • Pursuant to Regulation 2016/679 of the European Parliament and the Council (EU) (April 27, 2016) on the protection of natural persons with regard to processing personal data and on the free movement of such data, which cancelled Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the Regulation), Company provides you with the following information.


  • The controller of your personal data specified herein is Company
  • Company contact information on issues of personal data processing: postal address: Moscow, Perovskaja street, 20; e-mail: [email protected]

Personal Data and Purposes of Personal Data Processing

Personal data mean any information relating to the identified or being identified natural person (hereinafter referred to as the Personal Data). Company processes your Personal Data, including but not limited to, for the following purposes:
  • Registration and authentication of the User on the Website
  • Maintenance of Website operation
  • Identification of Users
  • Support of Users
  • Review of any applications, inquiries, claims, and offers
  • Giving advice to Users
  • Settlements and payments
  • Accounting of finance and protection of financial interests
  • Polling and analyzing the opinions of Users
  • Notifying and informing the Users
  • Statistics and the business analysis
  • Business planning and preparation of reports
  • Records management and book-keeping
  • Archiving of information
  • Auditing of Company systems
  • Prevention and investigation of IT safety incidents
  • Prevention and investigation of violations associated with Personal Data processing
  • Submission of information to public institutions
  • Submission of information to third parties if it is stipulated by laws and regulations
  • Promotion of the Company Services and marketing events
  • User-focused direct advertising
  • Marketing statistics collection
  • Analyzing the User’s habits
  • Organization and conducting of lotteries, contests, and draws

Legal Ground for Personal Data Processing

Company carries out processing of your Personal Data in the following events:
  • Personal Data processing is required for observance of legitimate interests of Company or any third party
  • Processing of your Personal Data is required for fulfillment of legal obligations specified in the laws and regulations applicable to Company
Company has the following legitimate interests:
  • Provide development of its commercial activity
  • Render, elaborate, and develop its Services, as well as ensure improvement thereof
  • Ensure positive relations with Users
  • Enhance servicing the Users
  • Ensure Services rendering
  • Prevent potential financial and managerial risks
  • Prevent legal risks
  • Prevent security risks
  • Protect its financial interests
  • Retain and attract Users
  • Maintain Website operability
  • Develop and make improvements for the Website
  • Ensure the use of Website by Users
  • Hold marketing events
  • Promote advertizing and distribution of Services
  • Inform society on its activity
  • Ensure public dimension of events organized by Company
  • Provide business management, analysis, and planning
  • Protect its rights, using services of authorized and competent institutions
Company has received your Personal Data processing consent in electronic form on the Website

Recipients and Sources of Personal Data

The User shall have the right to receive information associated with processing of their personal data, including the following:
  • Workers and authorized persons of Company who process Personal Data specified herein on behalf of Company within their powers and work tasks
  • Consultants of information systems and service providers for servicing thereof
  • Service providers engaged for studying the User’s opinions
  • Research service providers
  • Service providers who ensure communication with Users or send information to Users
  • Service providers engaged for Users servicing
  • Providers of postal and delivery services
  • Banks and other suppliers of settlement and financial services
  • Service providers who carry out exchange of information between Company and financial service providers
  • Creative and media agencies
  • Suppliers of advertising and marketing services
  • Sponsors and event managers
  • Service providers in charge of public relations
  • Company developers, managing directors, and solution providers
  • Insurance service providers
  • Legal service providers
  • Print media service providers
  • Security and safety service providers
  • Public institutions and their officers and officials if it is considered required or obligatory under the applicable laws and regulations
Company may obtain information about you from their partners who help Company to accept payments from you

Personal Data Processing Period

Your personal data are processed in the extent reasonably required depending on the specific purpose of data processing with adherence to the provisions of the laws and regulations in force
Company will store your Personal Data:
  • As long as it is required or permitted by the laws and regulations, and
  • As long as you use the Services of Company, and
  • As long as it is necessary to achieve the personal data processing purposes specified in Section 3 hereof

Your Rights Associated with Your Personal Data Processing

The right to access: you have the right to receive confirmation from Company to know whether your Personal Data are processed or not
The most of the user’s personal data is available to them during authentication in their user profile on the Website. If you need more information about your Personal Data, use the Company contact information specified in Section 2 hereof
All additional copies of your personal data which you request from Company may be charged with the fee by Company to reimburse its administration costs
If you send your request in electronic form, Company provides information in a widely used electronic format
The right to correct: in the event of any inaccuracies, you may request to have the inaccurate personal data corrected by Company
The right to remove: you shall be entitled to request Company to remove your Personal Data if:
  • You withdraw your consent to your Personal Data processing
  • Personal Data are not required any more for the purposes specified in Section 3 hereof for which they were processed
  • Personal Data are processed illegally; or
  • Personal Data shall be deleted according to the requirements of laws and regulations
You shall have the right to withdraw your consent to your Personal Data processing in such cases when the basis for Personal Data processing is your consent. If the consent is given when using the Website, you may withdraw your consent on the Website. In other events for your consent to be withdrawn, use the Company contact information specified in Section 2 hereof
If you withdraw your consent, inter alia for the use of cookies, Company shall have the right to limit functionality and scope of its Services, in particular a time frame of the Website as well as any related services if it depends on availability of the relevant Personal Data. In such cases, Company will not be able to render the corresponding Services to you because, due to your consent withdrawal, Company has no personal data necessary to ensure the Services and/or functionality
Withdrawal of consent does not influence on data processing which was carried out during validity of that consent
The right for removal does not pertain to cases when, pursuant to law, Company is obliged to process the Personal Data or when data processing is required for archiving, public interests or for statistical purposes, as well as in connection with submission, implementing or protection of a legal claim
The right for limitation of Personal Data processing: you shall have the right to demand Company limit your Personal Data processing if:
  • You challenge the accuracy or legitimacy of Personal Data processing
  • Personal Data processing is illegal but you object removing your Personal Data
  • Company does not need your Personal Data any more but you need them to file claims, exercise or protect your legal interests
The right to transfer: you have the right to obtain your Personal Data provided by you to Company, in a structured, widely used, and machine-readable format and may request for the mentioned data to be sent to another controller if it is technically feasible
The right to file a complaint: you shall have the right to file a complaint to Company as well as to the Data Official Inspectorate of the Russian Federation if you believe that your right to Personal Data protection has been or is violated

Computer-Aided Decisions for Personal Data Processing

In terms of your Personal Data there may be computer-aided decisions taken in the following cases
  • User profiling for mailing the personalized news; and
  • Settlement functions

Cookies-Based Processing of Personal Data

  • The information regarding the Personal Data processing, which is generated by means of cookies, is available on the Website
  • The Website may contain links to other websites. Company has no control over other websites. Company is not liable for protection and confidentiality of any information which you provide visiting those sites


Company is entitled to make amendments into the Policy. The updated Policy revision is available on the Website