1. Who we are
Ashword for iOS and Android (the “Game”) is made and published by Popiron: Dmitry Mikhailovich Galushko, a self-employed individual registered in Russia under the professional income tax regime, taxpayer ID (INN) 231123583140, contact address: dim.galuschko@yandex.ru (“Developer”, “we”).
The Developer is the operator (controller) of the personal data processed in connection with the Game under Russian Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (the “Law”). This Policy sets out how we process personal data (Article 18.1 of the Law). It covers the Game and the emails you send us about it. The Russian version of this Policy prevails.
The person responsible for organising data processing is Dmitry Galushko: dim.galuschko@yandex.ru.
2. In short
- The Game has no accounts and no sign-up. We never ask for your name, email or phone number.
- Your progress and settings stay on your device. The words you type in battle never leave it.
- On first launch the Game asks whether you agree to analytics and personalised ads. That is a separate document — the Consent to Personal Data Processing.
- If you decline, the Game works the same: analytics stay off and ads are not personalised.
- Without consent, only crash reports (VK LLC) and the technical data needed to show an ad (YANDEX LLC and VK LLC) are sent.
- Two Russian companies receive data: VK LLC (ООО «ВК») gets analytics, crash reports and the data for VK Ads, YANDEX LLC (ООО «ЯНДЕКС») gets what is needed for ads. Both store data in Russia.
- You can change your mind at any time in the Game’s settings.
3. What stays on your device
- your best result, run and camp progress, and completed lessons;
- your sound, music, vibration and language settings;
- your answer to the consent request, its date and the consent version;
- an ad log the Game uses to respect its ad frequency limits.
This data is never sent to us, we have no access to it, and it is deleted with the Game. If device backup is on (Google or iCloud), it may end up in your backup, which you and the platform control, not us.
4. What is processed, why, and on what basis
4.1. Crash reports — always
Service: Tracer (VK LLC).
Why: to find and fix errors and crashes.
Data: error type and message, stack trace, Game version and build, device model, OS version, language, the technical state of the device and app at the time of the crash (for example, free memory), Tracer’s internal installation ID, and the IP address the report came from. We never put the words you type into reports, but the message of an unexpected error may contain a technical fragment of the Game’s state.
Basis: performance of the Terms of Use, under which we provide a working Game (Article 6(1)(5) of the Law).
Retention: 90 days from receipt, after which Tracer deletes the report.
4.2. Showing ads — always, while the Game has ads
Services: Yandex Advertising Network (YANDEX LLC) and VK Ads (VK LLC). The Yandex module requests ads and runs an auction for each impression; VK Ads bids in it through its own ad module in the Game, and the network with the higher bid shows the ad. The Yandex module has AppMetrica built in: it runs inside the module, with Yandex’s keys, and sends Yandex technical information about how ads work. None of our events go into it. The Yandex module starts only after you answer the consent request, whatever your answer, and Yandex starts the VK Ads module when it calls it to the auction.
Why: to show an ad, credit a rewarded video, count impressions and prevent fraud. There are two kinds of ads:
- rewarded videos, which you choose to watch;
- interstitial ads between battles, at most once every five minutes.
Data:
- IP address and the country and region derived from it;
- the installation IDs of the ad modules and AppMetrica; the App Set ID and the advertising ID (GAID) on Android, the IDFV on iOS;
- device manufacturer and model, OS and version, system and keyboard languages, time zone, screen size and density, theme;
- memory size, battery level, time since the device was last started and whether it is rooted — VK Ads uses these to tell a real device from fraud;
- the Game and ad module versions;
- mobile carrier and connection type;
- ad impressions and clicks.
Without your consent the Game tells the networks not to match ads to your interests: Yandex directly, VK Ads through the Yandex module. On Android the ad modules may still read the GAID in that case. On iOS the IDFA is unavailable without consent: the Game shows the system tracking prompt only after “Accept”. The Game has no location permission, and location tracking is also turned off in the Yandex module.
Basis: performance of the Terms of Use: the Game is free because it shows ads (Article 6(1)(5) of the Law).
Retention: we do not store this data. YANDEX LLC and VK LLC process it as independent operators for the periods set in their policies: Yandex and VK Ads.
4.3. Analytics — only with your consent
Service: MyTracker (VK LLC).
Why: to see, in aggregate, how people play: where they quit, what is unclear in the tutorial, how the balance and ads work.
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;
- your answer to the consent request and the consent version;
- identifiers: the MyTracker installation ID; on Android, the App Set ID and the advertising ID (GAID); on iOS, the IDFV, and the IDFA only if you allow tracking in the system prompt;
- device model, OS and version, language, time zone, mobile carrier;
- IP address and the country, region and city derived from it;
- install source, launch times and session length.
Location tracking by GPS or Wi-Fi and device sensors are turned off in analytics.
Basis: your consent (Article 6(1)(1) of the Law).
Retention: while your consent is in force, but no longer than two years from receipt. If you withdraw consent, collection stops at once and the data collected is destroyed within 30 days (Article 21(5) of the Law).
4.4. Personalised ads — only with your consent
Services: Yandex Advertising Network (YANDEX LLC) and VK Ads (VK LLC), as in section 4.2.
Why: to match ads to your interests and measure how ads perform.
Data: everything in section 4.2, plus the advertising ID: GAID on Android (if you deleted it, VK Ads uses the Android ID), IDFA on iOS (only if you allow tracking).
Basis: your consent (Article 6(1)(1) of the Law).
Retention: YANDEX LLC and VK LLC process this data as independent operators for the periods set in their policies. Once you withdraw consent, the Game requests only non-personalised ads.
4.5. Emails to us
Why: to answer a question, look into a bug, or handle a data request.
Data: your email address, name (if you give it), the message and attachments, an installation or advertising ID (if you send one).
Basis: our legitimate interest in answering a message you chose to send (Article 6(1)(7) of the Law); for data requests, our duties as an operator (Article 6(1)(2) of the Law).
Retention: one year from the last message; correspondence about personal data requests, three years.
Correspondence is kept in a Yandex Mail mailbox.
5. What we do not do
- ask for or receive your name, phone number, contacts, photos or audio;
- determine your precise location;
- set a player ID in any service or link data to your identity;
- sell data or share it with anyone other than VK LLC and YANDEX LLC as described in section 4;
- process special categories of data or biometric data;
- make decisions with legal effect on you based solely on automated processing.
6. What we do with the data
Collection, recording, organisation, accumulation, storage, updating, retrieval, use, transfer (provision, access), anonymisation, blocking, erasure and destruction. Processing is automated, with transfer over the internet.
7. Who receives data
VK LLC (ООО «ВК», OGRN 1027739850962, Leningradsky Prospekt 39, bld. 79, Moscow 125167, Russia), the owner of MyTracker, Tracer and VK Ads:
- MyTracker and Tracer process data on our behalf, under the agreements for those services and only for the purposes in sections 4.1 and 4.3;
- VK Ads receives the data in sections 4.2 and 4.4 as an independent operator and processes it to serve ads under its own policy.
YANDEX LLC (ООО «ЯНДЕКС», OGRN 1027700229193, 16 Lva Tolstogo St., Moscow 119021, Russia), the owner of the Yandex Advertising Network and AppMetrica. It receives the data in sections 4.2 and 4.4 as an independent operator and processes it to serve ads under its own policy.
Service documents: Yandex privacy policy, VK Ads privacy policy, MyTracker legal documents, Tracer documents (at the bottom of the page).
App stores (the App Store, Google Play, RuStore) receive installation and device information under their own rules. We do not share data with them.
Public authorities receive data only where the law expressly requires it.
8. Where data is stored
Data is stored and processed in Russia: in VK LLC’s and YANDEX LLC’s databases and in a Yandex Mail mailbox. Personal data of Russian citizens is recorded, organised, accumulated, stored, updated and retrieved using databases located in Russia (Article 18(5) of the Law). We do not transfer data out of Russia. If you play outside Russia, your data is transferred to Russia — for players in the EU and the UK, see section 12.
9. How data is destroyed
Data is destroyed once the period in section 4 ends, the purpose is achieved or you withdraw consent — within 30 days. If processing turns out to be unlawful, we stop it within three working days and, if it cannot be made lawful, destroy the data within ten working days (Article 21 of the Law). Destruction is documented as required by Roskomnadzor (Order No. 179 of 28.10.2022).
10. How we protect data
- Services receive data over an encrypted connection.
- The Game sends only what each purpose needs: no player ID, no typed words, no location.
- Only the Developer has access to the MyTracker, Tracer, Yandex Advertising Network and VK Ads accounts and to the mailbox.
- We keep the service modules up to date and follow changes in their terms.
11. Your rights
You have the right to know what data about you is processed and how; to have it corrected, blocked or destroyed; to withdraw consent; and to complain about us to Roskomnadzor or a court (Articles 14 and 17 of the Law).
How to do it:
- withdraw or give consent again — in the Game’s settings, the “Analytics and personalised ads” switch;
- block tracking on iOS — Settings › Privacy & Security › Tracking;
- reset or delete the advertising ID on Android — Settings › Google › Ads (the path varies by device);
- erase everything on the device — delete the Game;
- anything else — email dim.galuschko@yandex.ru. So we can find your data, include the installation ID shown in the Game’s settings.
We reply within 10 working days. We may extend this by 5 more working days and will tell you why in advance (Article 20(1) of the Law).
12. Players in the European Union and the United Kingdom
If you are in the EU, the European Economic Area or the UK, the General Data Protection Regulation (GDPR and UK GDPR) also applies to your data. The Developer is the controller.
Legal bases: analytics and personalised ads — your consent (Art. 6(1)(a) GDPR); crash reports and non-personalised ads — performance of the Terms of Use (Art. 6(1)(b)) and our legitimate interest in a working free Game (Art. 6(1)(f)); emails — legitimate interest and compliance with GDPR duties.
Transfer to Russia. VK LLC and YANDEX LLC store data in Russia. Russia has no adequacy decision, and we do not use standard contractual clauses. Therefore:
- for analytics and personalised ads, the transfer relies on your explicit consent (Art. 49(1)(a) GDPR). The consent screen states plainly that the data is stored in Russia and that for the EU and UK this means no GDPR protection; the consent text sets out the risks in full: your rights there are protected by different law, and public authorities may access data on terms different from those in the EU;
- for crash reports and non-personalised ads, the transfer is necessary to perform the Terms of Use (Art. 49(1)(b) GDPR).
Your rights: access, rectification, erasure, restriction, portability, objection to processing based on legitimate interest, and withdrawal of consent at any time without affecting earlier processing. Email dim.galuschko@yandex.ru; we reply within one month. You may also lodge a complaint with the data protection authority in your country.
13. Children
The Game is for people aged 16 and over (rated 16+ under Russian Federal Law No. 436-FZ). If you are under 16, do not give consent: choose “Decline” on the consent screen. If you learn that a child under 16 has given consent, email us and we will destroy their data.
14. Changes
A new version is published on this page with a new date and number. If there are new purposes or new recipients of data, the Game will ask for consent again. Earlier versions are available on request.
15. Contact
Popiron, Dmitry Galushko, dim.galuschko@yandex.ru, popiron.ru.