PERSONAL DATA PROCESSING POLICY of the social network "Gamer.ru"
Data Operator: Individual Entrepreneur Polyakov Vladimir Vladimirovich, OGRNIP 325774600714063, INN 772152688090
Website: https://www.gamer.ru/ (hereinafter — Service)
E-mail for inquiries regarding PD: info@gamer.ru
Responsible for PD: Individual Entrepreneur Polyakov Vladimir Vladimirovich
Acceptance. By registering and/or using the Service, the User accepts this Consent to the processing of personal data and the terms of this Policy. Separate consents (for the dissemination of PD, for marketing messages, and others, if applicable) are provided and revoked separately in the Service interface.
1 General Provisions
1.1. The Policy has been developed and published by the Operator in accordance with the legislation of the Russian Federation to inform about the procedure for processing personal data of Service users (hereinafter — Users).
1.2. The Policy applies only to information processed by the Operator when using the Service. The Service may contain links/embed components of third parties, for which the respective entities are responsible for data processing.
1.3. The Policy is publicly available and is posted at: https://www.gamer.ru/info/policy. The Policy may only be amended by publishing a new version at the specified address.
2 Terms
2.1. Personal data (PD) — any information about an identified or identifiable individual.
2.2. Processing PD — any action/set of actions with PD (collection, recording, systematization, storage, clarification, use, transfer, anonymization, blocking, deletion, destruction).
2.3. Operator — a legal entity that independently or jointly with other entities organizes and/or carries out the processing of personal data and also determines the purposes of processing personal data, their composition subject to processing, actions (operations) performed with Users' personal data.
2.4. Dissemination of PD — providing PD to an unlimited number of individuals (including through public profile/content).
2.5. ISPD — information systems of personal data of the Operator.
3 Data Categories and Sources
3.1. The Operator processes the following aggregated categories of PD:
a) Account data and contacts: nickname, e-mail, telephone (when linked), account ID;
b) Profile and content: avatar/description, publications, comments, reactions;
c) Technical data: cookies/device ID, IP address, User-Agent, language/time zone, event logs;
d) Payment metadata (for paid functions): status/identifier of transactions with the payment agent (without storing full details with the Operator);
e) Communications: inquiries to support/moderation, notifications;
f) Data from external services — at the User's choice when signing in through third-party social networks and linking accounts.
3.2. Special and biometric PD are not intentionally processed by the Operator. Their processing and/or dissemination are possible only with the required separate consents as mandated by law.
4 Purposes and Legal Grounds
4.1. Purposes of processing:
a) account registration and maintenance;
b) providing Service functions (feed, publications, comments, recommendations, search, subscriptions, notifications, chats);
c) moderation, protection against abuse/fraud, ensuring security and operability;
d) processing Users' inquiries;
e) fulfilling legal obligations (including accounting and other mandatory records, responses to legitimate requests from governmental authorities);
f) analytics and improvement of the Service;
g) marketing messages.
4.2. Legal grounds: user agreement (contract), consent of the PD subject, fulfillment of legal obligations, as well as the Operator's legitimate interests while respecting Users' rights and freedoms.
5 Cookies and Identifiers
5.1. The Service uses cookies/device IDs for authentication, personalization, analytics, abuse protection, and performance measurement.
5.2. Management — through browser/device settings and privacy sections in accounts; limiting the use of cookies may affect the operation of the Service.
6 Conditions of Processing and Transfer to Third Parties
6.1. PD processing is conducted automatically and/or non-automatically in the Operator's ISPD with confidentiality maintained.
6.2. Transfer of PD to third parties is allowed if: (a) there is the User's consent; (b) the transfer is necessary for providing Service functions/fulfilling the contract; (c) the transfer is provided by law; (d) anonymized data is transferred for research/providing services on behalf of the Operator; (e) within the framework of reorganization/business transfer to a successor while complying with this Policy.
6.3. Engaged processors (hosting/DC, CDN, anti-fraud/anti-spam, analytics, mailings, technical support, development) act based on contracts and data protection requirements.
**7 Profile Publicity and