You give this consent in Ashword (the “Game”): with the “Accept” button on the consent screen at first launch, or with the “Analytics and personalised ads” switch in the settings. The consent is a separate document: it is not part of the Privacy Policy or the Terms of Use. The Russian version of this document prevails.
Giving it is optional. If you decline, the Game works the same: analytics stay off and ads are not personalised.
Consent text
I, a user of the Game, freely, of my own will and in my own interest, give consent to Dmitry Mikhailovich Galushko, a self-employed individual under the Russian professional income tax regime, taxpayer ID (INN) 231123583140, contact address: dim.galuschko@yandex.ru (the “Operator”), to process my personal data on the terms below.
1. Purposes
- Analytics: to see, in aggregate, how people play the Game, so as to fix errors and improve the tutorial and the balance.
- Personalised ads: to match ads to my interests and measure how ads perform.
2. Data
- Game events: run start and end, depth reached and score, reward and path choices, camp upgrades, tutorial steps, word rejections with their reason (never the word itself), language changes, ad offers and impressions;
- my answer to the consent request and the version of this document;
- the MyTracker installation ID; on Android, the App Set ID and the advertising ID (GAID); on iOS, the IDFV, and the IDFA only if I allow tracking in the system prompt;
- device model, operating system and version, language, time zone, mobile carrier and connection type;
- IP address and the country, region and city derived from it;
- install source, launch times and session length;
- for personalised ads: the advertising ID (GAID, or the Android ID if it was deleted; the IDFA only with iOS permission), the installation IDs of the ad modules and the AppMetrica built into the Yandex module, the App Set ID (Android), the IDFV (iOS), the Game and ad module versions, screen size and density, theme, keyboard languages, memory size, battery level, time since the device was last started, and whether it is rooted;
- ad impressions and clicks.
3. What may be done with it
Collection, recording, organisation, accumulation, storage, updating, retrieval, use, transfer (provision, access), anonymisation, blocking, erasure and destruction. Processing is automated, with transfer over the internet.
4. Who receives it
- VK LLC (ООО «ВК», OGRN 1027739850962, Leningradsky Prospekt 39, bld. 79, Moscow 125167, Russia): the MyTracker service processes data for purpose 1 on the Operator’s behalf, and the VK Ads service receives data for purpose 2 and processes it as an independent operator under its own policy;
- YANDEX LLC (ООО «ЯНДЕКС», OGRN 1027700229193, 16 Lva Tolstogo St., Moscow 119021, Russia): the Yandex Advertising Network receives data for purpose 2 and processes it as an independent operator under its own policy. VK Ads bids for impressions inside its auction.
The data is stored in Russia.
5. Duration
This consent is valid until I withdraw it. Data for purpose 1 is kept for no longer than two years from receipt.
6. How to withdraw
Turn off the “Analytics and personalised ads” switch in the Game’s settings, or write to the Operator at dim.galuschko@yandex.ru. After withdrawal, collection stops at once, and the data collected is destroyed within 30 days unless the law provides another basis for processing it (Articles 9(2) and 21(5) of Federal Law No. 152-FZ).
7. I confirm that
- I am 16 or older;
- I have read the Privacy Policy and understand what data the Game processes without consent: crash reports and the technical data needed to show non-personalised ads.
For players in the European Union and the United Kingdom
By choosing “Accept”, I also explicitly consent to the transfer of the data listed above to Russia (Art. 49(1)(a) GDPR). I understand the risks: Russia has no adequacy decision, no standard contractual clauses apply, my rights there are protected by Russian law, and public authorities may access the data on terms different from those in the EU.
How consent is recorded
The Game stores on the device the date and time of my answer and the version of this document. When I consent, the same details are sent to MyTracker as an event, so the Operator can prove that consent was given (Article 9(3) of Federal Law No. 152-FZ). If this document changes in substance, the Game will ask for consent again.