Privacy Policy

1. General Provisions
This privacy policy is compiled in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by "Игра Первых" (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms when processing their personal data, including the protection of the right to privacy, personal and family secrets, to be its most important goal and condition for its activities.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://gameoffirsts.ru and users of the mobile application "Game of Firsts" (hereinafter referred to as the Application).

2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of the processing of personal data (except when processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as programs for computers and databases, ensuring their availability on the Internet at the network address https://gameoffirsts.ru.
2.4. Information system of personal data — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data — actions resulting in it being impossible to determine, without using additional information, to whom the personal data belongs.
2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) performing the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data — any information related directly or indirectly to a specific or identifiable User of the website https://gameoffirsts.ru or the Application.
2.9. Personal data allowed by the subject of personal data for distribution — personal data, access to which is provided to an unlimited number of persons by the subject of personal data through their consent to the processing of personal data allowed for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).
2.10. User — any visitor to the website https://gameoffirsts.ru or user of the Application.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an indefinite circle of persons with personal data, including making personal data public in the media, placing it in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign natural or foreign legal person.
2.14. Destruction of personal data — any actions resulting in the irrevocable destruction of personal data with the impossibility of further recovery of the content of personal data in the personal data information system and (or) resulting in the destruction of tangible media containing personal data.

3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the subject of personal data;
— in case of revocation by the subject of personal data of consent to the processing of personal data, as well as in case of sending a request to stop processing personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data, upon their request, with information concerning the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of subjects of personal data, upon request of this body, the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— fulfill other obligations provided for by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— set a condition for prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— revoke consent to the processing of personal data, as well as send a request to stop processing personal data;
— appeal to the authorized body for the protection of the rights of subjects of personal data or to the court against illegal actions or inaction of the Operator when processing their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate data about themselves;
— inform the Operator about clarifying (updating, changing) their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate goals. It is not allowed to process personal data incompatible with the purposes of collecting personal data.
5.3. It is not allowed to combine databases containing personal data whose processing is carried out for purposes incompatible with each other.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, their relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption for removing or clarifying incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows identifying the subject of personal data no longer than required by the purposes of processing personal data unless the period of storage of personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or if there is no longer a need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

|Purpose of ProcessingPersonal DataLegal GroundsTypes of Personal Data ProcessingProviding User access to services, information, and/or materials on the website and in the mobile applicationLast name, first name, patronymic, email addressCharter documents of the Operator, contracts between the Operator and the personal data subjectCollection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data. Sending informational emails to the email address


7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform the functions, powers, and duties assigned to