These Rules define the Operator's policy regarding the processing of personal data when operating the mobile application, website and server-based consent recording system RandomSet.RU.
1. General provisions
1.1. The Rules were developed in accordance with the Constitution of the Russian Federation, Federal Law dated July 27, 2006 No. 152-FZ “On Personal Data” and other applicable acts.
1.2. The Operator proceeds from the principles of legality, fairness, limitation of processing to specific purposes, data minimization, accuracy, limited storage periods and security.
1.3. The Rules apply to automated processing in the Application, on the website and server, as well as mixed processing of requests.
1.4. The The The The Consent Recording API (application programming interface for recording consents) is part of the server system through which the Application transmits information about the acceptance of legal documents and the selected type of advertising. It does not provide users with the ability to publicly view saved entries.
1.5. Unique Installation Identifier (UUID) is a randomly generated code that distinguishes one installation of the Application from another and does not contain the User's name, phone number or email address.
2. Information about the Operator
| Operator | Pavel Andreevich Kiselev |
|---|---|
| Status | an individual applying the special tax regime “Professional Income Tax” (self-employed) |
| Address | 117403, Russian Federation, Moscow, Biryulyovo Zapadnoye Municipal District, 3 Kharkovskaya St., Bldg. 8, Apt. 108 |
| info@1294studio.ru |
3. Scope of processing
3.1. The Application does not create an account, does not request geolocation, and does not transmit random selection results to the server.
3.2. RandomSet.RU's own server database is designed to consistently record legal actions using a unique installation identifier. The ability to retrieve, modify or delete these records through the public server interface is not provided.
3.3. To download and display the selected type of advertising on the device, the Yandex Mobile Ads SDK, an embedded component provided by YANDEX LLC for loading and displaying advertising and recording interactions, is used.
4. Categories of data subjects
- users of the Application;
- visitors to the RandomSet.RU website;
- persons sending requests to the Operator.
5. Categories of data
5.1. A unique installation identifier, the selected type of advertising, information about the acceptance of legal documents, the number of the accepted edition, as well as the date and time the information was received by the server.
5.2. Technical logs: device network address (IP address), date and time of access, address of the requested page or function, result of the access, information about the device, operating system or browser, errors and security events.
5.3. Advertising: advertising identifier - code provided by the operating system for advertising to work, and other technical identifiers; information about the device, operating system, Application, network, ad impressions, click-throughs and other interactions to the extent necessary for the selected type of advertising.
5.4. Support: email, name, message text, technical information and attachments voluntarily sent by the User.
5.5. Special categories and biometric data are not requested by the Operator. The results of the random selection are not transmitted to the server.
6. Purposes, legal bases and retention periods
| Purpose | Data | Legal basis | Storage period |
|---|---|---|---|
| Recording acceptance of documents and the selected type of advertising | Unique installation identifier; selected type of advertising; information about the acceptance of legal documents; their revision number; date and time of receipt of information | Consent in the applicable part and confirmation of the conclusion of the User Agreement | Up to 3 years after the last entry |
| Operation and protection of the server interface and website | IP address; date and time of request; requested address; query result; device or browser information; technical errors and security events | Legitimate interest in performance and security | Generally up to 90 days; incident data - until the investigation is completed |
| Non-personalized advertising | Device network address (IP address); information about the device, operating system, Application and network; information about the advertising unit, impressions and interactions | Performance of the Terms of Use; applicable grounds for participants in the advertising infrastructure | The Operator does not store them separately, except for the selected type of advertising and logs; for recipients — in accordance with their policies |
| Personalized advertising | Advertising and technical identifiers; information about the device, OS, Application, network and advertising interactions | Separate consent of the User | Until Consent is withdrawn; thereafter, in accordance with the relevant recipients’ policies and mandatory requirements |
| Support | Email, name, content of the request, technical information and attachments sent by the User | Consent, consideration of the request and protection of rights | Until completion of the request and, as a rule, no more than 3 years after the last interaction |
7. Obtaining and recording Consent
7.1. Before processing based on Consent, the User receives a separate text of consent and takes an active action in the interface.
7.2. Acceptance of the User Agreement, familiarization with the Policy, consent to the processing of a unique installation identifier and information about legal actions, as well as consent to personalized advertising are taken into account separately.
7.3. The server receives a unique installation identifier, the selected type of advertising, information about acceptance of the User Agreement, Privacy Policy and Consent to the processing of personal data, as well as the number of the accepted document revision. The date and time of receipt of this information is recorded by the server.
7.4. A missing or zero document revision number is not recognized as confirmation of acceptance of the current edition.
7.5. When information is resubmitted, the server creates a new record. Previously generated records are saved unchanged to confirm the sequence of User actions.
8. Advertising and interaction with YANDEX LLC
8.1. Personalized advertising is only enabled with separate Consent. The selected setting is transferred to the Yandex Mobile Ads SDK. Consent is withdrawn by switching to non-personalized advertising in the Application settings.
8.2. Non-personalized advertising may require technical data processing for delivery, accounting, frequency limiting, security and fraud prevention purposes.
8.3. Geolocation is not requested by the Application and coordinates are not intentionally transmitted through advertising integration.
9. Actions with data
9.1. Processing may include collection, receipt, recording, systematization, accumulation, storage, clarification, retrieval, use, provision to designated persons, anonymization, blocking, deletion and destruction.
9.2. The Operator does not make decisions that give rise to legal consequences for the User solely on the basis of automated processing.
10. Data transfers and delegated processing
10.1. Data may be disclosed to hosting, server, network, mail and security infrastructure providers only to the extent necessary to provide the relevant service.
10.2. YANDEX LLC and participants in the advertising infrastructure receive data through the Yandex Mobile Ads SDK for displaying advertising and process it in accordance with contractual terms, their own policies and applicable legal grounds.
10.3. Data is provided to government agencies and other persons only in cases and in the manner prescribed by law.
11. Localization and cross-border transfer
11.1. Primary processing of data entering the server database of RandomSet.RU is carried out using a database located on the territory of the Russian Federation, regardless of the citizenship and location of the User.
11.2. The Operator does not carry out its own cross-border transfer of this database. Before such transfer begins, the Operator will complete the procedures required by law and update the documents.
12. Rights of personal data subjects
12.1. The User has the right to receive information about the processing of their personal data.
12.2. The User has the right to demand clarification, blocking or deletion of personal data in cases provided for by law.
12.3. The User has the right to revoke Consent to the processing of personal data directly in the Application by selecting: “Settings” → “About the Application” → “Withdraw consent to data processing.”
12.4. The User has the right to revoke Consent to personalized advertising by selecting non-personalized advertising in the Application settings.
12.5. The User has the right to demand termination of the processing of their personal data, except in cases where the Operator has the right to continue processing on the grounds provided for by law.
12.6. The User has the right to file a complaint about the Operator’s actions or omissions with Roskomnadzor or bring a claim before a court.
12.7. General requests and appeals are sent by email to info@1294studio.ru or to the Operator's postal address and are considered in the manner and within the time limits established by the legislation of the Russian Federation.
12.8. The Operator has the right to request information necessary to confirm the identity of the applicant and their authority. In this case, the Operator does not request data that is redundant with respect to the purpose of the verification.
13. Termination of processing
13.1. Processing is terminated upon achievement of the purpose, expiration of the period, withdrawal of Consent, detection of unlawful processing, or in other cases established by law.
13.2. Withdrawal of consent does not terminate processing for which there is another legal basis, including the storage of evidence of legal actions within the required period.
14. Security measures
- assignment of a person in charge and access control;
- encryption of a network connection and secure administration;
- verification of incoming data and restriction of acceptable methods of accessing the server;
- prohibiting public read access to the Consent database and applying least-privilege access to database accounts;
- logging, updating, backup and recovery of server systems;
- incident monitoring and periodic review of measures.
15. Incidents
15.1. If unauthorized access, transfer or loss of data is detected, the Operator contains the breach, conducts an investigation, assesses the consequences, takes recovery measures and interacts with Roskomnadzor in the manner and within the time limits established by law.
16. Control and updating
16.1. The Operator monitors the compliance of the processing of personal data with these Rules and updates them when legislation, purposes and methods of processing, data composition, list of recipients or architecture of RandomSet.RU change.
17. Liability
17.1. The Operator is responsible for compliance with the requirements for the processing and protection of personal data within the limits established by the legislation of the Russian Federation.
17.2. The User is responsible for the security of their device and system account, as well as for the accuracy of information and materials voluntarily sent to the Operator when contacting by email.
18. Final provisions
18.1. These Rules are valid until they are replaced by a new edition.
18.2. Significant changes to the Rules are brought to the attention of the User through the Application or the RandomSet.RU website before they take effect.
18.3. If changes affect the processing of personal data carried out on the basis of Consent, the text of the relevant Consent is updated and a new Consent is requested before such processing begins.
18.4. The current version of the Rules is published at: https://randomset.ru/personal-data-processing-rules
19. Contacts
| Operator | Pavel Andreevich Kiselev |
|---|---|
| Status | individual applying the special tax regime “Professional Income Tax” (self-employed) |
| Address | 117403, Russian Federation, Moscow, Biryulyovo Zapadnoye Municipal District, 3 Kharkovskaya St., Bldg. 8, Apt. 108 |
| info@1294studio.ru |
Related documents
Terms of Use: https://randomset.ru/terms
Privacy Policy: https://randomset.ru/privacy
Consent to the processing of personal data: https://randomset.ru/personal-data-consent
Consent to personalized advertising: https://randomset.ru/personal-ads-consent