Privacy Policy

1. GENERAL PROVISIONS

1.1. This Privacy Policy (the “Policy”) describes how personal data of users (the “User”) of the Slovoblood application (Russian: «Словоблуд»), which operates as a Telegram Mini App, as well as the related Telegram bot and the information website (together, the “Service”), is collected, processed, stored and protected.

1.2. The operator of personal data processing is Evgeny Vasilyevich Rogachev (Russian: Рогачев Евгений Васильевич), an individual applying the special tax regime “Tax on Professional Income” (self-employed) (the “Operator”).

1.3. Operator contact details: e-mail — slovobloodbot@yandex.ru; support — the Telegram bot WTGAdminBot.

1.4. By starting to use the Service, the User confirms that they have read this Policy and consent to the processing of their personal data on the terms set out in it. A User who does not agree with the terms of the Policy must stop using the Service.

1.5. The project’s information website does not collect personal data of visitors, except for the technical information described in section 3.7 of this Policy (when cookies are used), because it provides no registration or authorization and serves solely as a way to open the Telegram Mini App.

2. LEGAL BASES FOR PROCESSING

2.1. Personal data is processed on the basis of: the User’s consent, expressed by starting to use the Service and taking actions in it (for Users located in the Russian Federation — in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”); the necessity of performing the User Agreement between the Operator and the User; the Operator’s legitimate interests in keeping the Service operational, secure and developing; and the requirements of applicable law.

2.2. For Users located in the European Union or the European Economic Area, processing is additionally carried out in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”), and for Users in the United Kingdom — in accordance with the UK GDPR, on the basis of Article 6(1)(b) (performance of a contract), Article 6(1)(a) (consent) and Article 6(1)(f) (legitimate interests) of the respective regulations.

2.3. For Users located in the State of California (USA), this Policy takes into account the requirements of the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act, with regard to the rights of access, deletion and opt-out of the sale of personal data. The Operator does not sell Users’ personal data to third parties.

3. WHAT DATA IS COLLECTED

3.1. Data provided by the Telegram platform when the Service is used: Telegram ID (a unique account identifier); username (the Telegram username, if set); the profile display name; the profile picture (avatar), if available and provided by Telegram; the account language settings.

3.2. Data about use of the Service: game progress, including levels, points and ranking; statistics of game sessions and activity; achievements and rewards; information about purchased and used digital game items, including transactions made with Telegram Stars (the Operator has no access to the User’s payment credentials, which are processed by the Telegram platform).

3.3. User content: topics, word collections, definitions, suggestions and other materials that the User voluntarily submits to the Service.

3.4. Support requests: the content of requests sent through the Telegram bot WTGAdminBot or by e-mail, including technical data connected with the request (Telegram ID, time of the request).

3.5. Technical data and logs: data about technical events, errors and actions in the Service that is needed to keep the Service operational, diagnose failures and prevent abuse (including data used for the purposes described in section 10, “Anti-cheat”).

3.5.1. Button-press statistics: the Operator records which interface buttons of the application and of the Telegram bot menu the User presses, as well as the total number of presses of each button by all Users; the number of presses by each individual User is not recorded. Only the conventional name of the button is recorded (for example, “open shop”); message texts and words entered by the User, and the names and identifiers of collections, words and chats, are not included in this record. For the bot, the type of chat (private chat, group, channel) is also stored. Presses are summed by day; to count the number of distinct players, the Telegram ID of the person who pressed is stored together with them. This information is used only to assess which features of the Service are in demand and to improve the interface; in the administration panel it is available only as aggregate counters, with no export of an individual User’s actions. Presses by guests without a Telegram account are recorded without an identifier.

3.6. Information about the Telegram client version, device type and platform (to the extent provided by the Telegram Mini Apps API), used for correct display and operation of the interface.

3.7. Cookies of the information website: where the project’s information website uses technical cookies, they are used solely to keep the website working and (where applicable) to collect anonymized visitor statistics. The website’s cookies do not collect personal data, because the website provides no registration or authorization.

3.8. The Operator does not collect special categories of personal data (information on health, religious or political beliefs, racial or ethnic origin, etc.) and does not ask Users for such data.

4. PURPOSES OF PROCESSING

4.1. Personal data is processed for the following purposes: operating the Service and providing access to its features; identifying the User within the game profile; building rankings and granting rewards and achievements; processing and moderating User content; processing transactions with digital game items and Telegram Stars; preventing fraud, cheating and other violations of the User Agreement; handling support requests; improving the functionality and quality of the Service; and complying with applicable law.

4.2. The Operator does not use Users’ personal data for purposes unrelated to the operation and development of the Service without the User’s additional consent, except where provided by law.

5. DATA RETENTION

5.1. Personal data is stored for the whole period during which the User uses the Service and for the period necessary to achieve the purposes of processing set out in section 4, unless a longer retention period is required by applicable law (in particular, for data on financial transactions).

5.2. If the User’s Account is deleted at the User’s request (section 8), the Operator deletes or anonymizes the personal data within a reasonable period not exceeding 30 (thirty) calendar days, except for data whose retention is required by applicable law (for example, data on transactions made with Telegram Stars) or is necessary to protect the Operator’s legitimate interests in connection with previously identified violations (anti-cheat data).

5.2.1. Daily button-press counters (clause 3.5.1) that contain a Telegram ID are stored for 90 (ninety) days and are then deleted automatically.

5.3. Anonymized and aggregated statistics that do not allow an individual User to be identified may be stored by the Operator without a time limit.

6. BACKUPS

6.1. To keep data safe and to restore the Service after technical failures, the Operator makes backup copies of data, including Users’ personal data.

6.2. Backups are stored in a protected form and are deleted or overwritten in accordance with the Operator’s internal backup rotation schedule, but no later than a reasonable period after the retention period of the relevant data specified in section 5 has expired.

7. TRANSFER OF DATA TO THIRD PARTIES AND CROSS-BORDER TRANSFER

7.1. The Operator does not sell Users’ personal data to third parties.

7.2. Personal data may be transferred to the following categories of third parties, to the extent necessary to achieve the purposes set out in section 4: the Telegram platform — to the extent unavoidable for the Service to operate as a Telegram Mini App and Telegram bot, and in accordance with Telegram’s own privacy policy; hosting and cloud infrastructure providers that ensure the technical operation of the Service and the storage of its data; other technical service providers (analytics, technical support) acting on the Operator’s instructions and obliged to keep the data they receive confidential; and government authorities — in cases expressly provided for by applicable law.

7.3. Data may be processed using servers located outside the User’s country of residence, including within the infrastructure of the Telegram platform and the cloud providers used by the Operator. In the event of cross-border transfer, the Operator takes reasonable measures to ensure a level of data protection comparable to the requirements of applicable law, including, where applicable, the use of standard contractual clauses or other recognized transfer mechanisms provided for by the GDPR / UK GDPR.

8. USER RIGHTS

8.1. The User has the right to: obtain confirmation that their personal data is being processed and review the data processed; request correction of inaccurate or incomplete data; request deletion of their personal data (the right to erasure / “right to be forgotten”) to the extent and in the manner not contradicting section 5 of this Policy; withdraw previously given consent to the processing of personal data, which may make it impossible to continue using the Service; for Users from the EU/EEA and the United Kingdom — additionally, to exercise the right to restriction of processing, the right to data portability and the right to object to processing carried out on the basis of the Operator’s legitimate interests; for Users from California — additionally, to obtain information on the categories of data collected and the purposes of collection, and to confirm that the Operator does not sell personal data.

8.2. To exercise these rights, the User sends a request through the Telegram bot WTGAdminBot or by e-mail to slovobloodbot@yandex.ru. The Operator reviews the request and replies within a period not exceeding 30 (thirty) calendar days, unless a shorter period is established by applicable law.

8.3. The Operator may ask the User for additional information needed to confirm their identity (to the extent available from Telegram data) in order to prevent unlawful disclosure of personal data to third parties.

9. DATA PROTECTION MEASURES

9.1. The Operator takes reasonable technical and organizational measures to protect Users’ personal data against unlawful access, destruction, alteration, blocking, copying, distribution and other unlawful actions by third parties, including: restricting access to data on the need-to-know principle; using technical means of protecting the server infrastructure; regular data backups; and supervision of contractors processing data on the Operator’s behalf.

9.2. Despite the measures taken, the Operator cannot guarantee absolute protection of data against all possible threats, including those arising from circumstances beyond the Operator’s reasonable control.

10. USE OF DATA FOR ANTI-CHEAT AND SECURITY PURPOSES

10.1. To keep gameplay fair and to prevent abuse, the Operator may analyze data on the User’s activity in the Service (technical logs, action statistics, patterns of use of User content) to detect signs of cheating, fraud, multi-accounting and other violations of the User Agreement.

10.2. Such data may be stored longer than the general period specified in section 5, to the extent and for the period reasonably necessary to protect the legitimate interests of the Operator and other Users of the Service.

11. CHILDREN AND AGE RESTRICTIONS

11.1. The Service is not intended for the deliberate collection of data about children below the age from which applicable law and the rules of the Telegram platform allow such services to be used independently, without the consent of parents or legal guardians.

11.2. If the Operator becomes aware that personal data has been provided by a person who has not reached the applicable age, without proper consent of a parent or legal guardian, the Operator takes reasonable measures to delete such data.

12. CHANGES TO THE PRIVACY POLICY

12.1. The Operator may amend this Policy. The current version is published in the Service and (or) on the project’s information website, stating the date it takes effect.

12.2. Continued use of the Service after the amendments take effect means the User’s agreement to the new version of the Policy. In the case of material changes affecting the scope or purposes of data processing, the Operator takes reasonable steps to additionally inform Users by means available within the Service.

13. FINAL PROVISIONS

13.1. This Policy is an integral part of the User Agreement of the Slovoblood Service.

13.2. If any provision of this Policy is held invalid, this does not affect the validity of its other provisions.

13.3. On matters relating to the processing of personal data, the User may also contact the authority responsible for protecting the rights of data subjects at their place of permanent residence, where provided by applicable law.

13.4. This Policy is drawn up in Russian. The English translation (/privacy/en) is provided for the User’s convenience only; in case of any discrepancy between the Russian and English texts, the Russian text prevails and has legal force.

14. OPERATOR CONTACT INFORMATION

Operator: Evgeny Vasilyevich Rogachev (Рогачев Евгений Васильевич), an individual applying the special tax regime “Tax on Professional Income”.

E-mail: slovobloodbot@yandex.ru

Support: Telegram bot WTGAdminBot