Privacy Policy

1. General provisions

1.1. This Policy explains in an accessible form what data is processed when using the RandomSet.RU mobile application for Android and iOS (hereinafter referred to as the Application), the website https://randomset.ru/ and the server-based consent recording system.

1.2. The Application provides random selection tools. No registration, account or user profile is created. Geolocation is not requested.

1.3. The Policy was developed taking into account the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”. The complete document defining the Operator's policy is the Personal Data Processing Rules.

1.4. The Rules are located at: https://randomset.ru/personal-data-processing-rules

1.5. Consent to the processing of personal data to account for the acceptance of legal documents and the selected type of advertising is a separate document and is posted at: https://randomset.ru/personal-data-consent

1.6. Consent to the processing of personal data for personalized advertising is a separate document and is located at: https://randomset.ru/personal-ads-consent

1.7. 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 is not intended for public viewing or public retrieval of stored entries.

2. Information about the Operator

3. What data is processed

3.1. To take into account the acceptance of legal documents and the selected type of advertising, the following are processed:

• unique installation identifier of the Application (UUID) - a randomly generated code that distinguishes one installation of the Application from another;
• type of advertising selected by the User: personalized or non-personalized;
• information about acceptance of the User Agreement, familiarization with the Privacy Policy and provision of Consent to the processing of personal data;
• revision number of the legal documents accepted by the User;
• date and time of receipt of the specified information by the server.

3.2. For the operation and protection of the site and the server-based consent recording system, the following may be processed:

• device network address (IP address);
• date and time of access;
• address of the requested page or function and the result of the access;
• information about the device, operating system or browser;
• error messages and security events.

3.3. To display advertising and record interactions with it, the built-in Yandex software component can process:

• device network address (IP address) and information about the network connection;
• information about the device, operating system and version of the Application;
• information about the advertising unit, impressions, transitions and other interactions with advertising;
• advertising personalization settings selected by the User.

An advertising identifier is a code provided by the operating system for advertising purposes. It and other technical identifiers may be used to personalize advertising only with a separate User Consent.

3.4. When contacting the Operator via email, the sender's address, name, content of the request, information about the issue, device model, version of the operating system and Application, screenshots and other materials voluntarily sent by the User can be processed.

The User should not send personal data of third parties or other information not related to the subject of the request. Incidentally obtained redundant information is not used to review the request and is deleted or masked whenever possible.

3.5. The Operator does not request passport, payment, biometric data or health information. The Application does not request access to the device's geolocation. The results of the random selection are generated locally on the device and are not sent to the Operator’s server.

4. Purposes and grounds of processing

4.1. The data is processed to fulfill the User Agreement, record the acceptance of legal documents, display the selected type of advertising, technical operation and protection of the service, consider requests and comply with legal requirements.

4.2. The legal basis is determined by the specific purpose: execution of the Terms of Use — to provide the requested functions; legitimate interests of the Operator - for diagnostics, security and abuse prevention; separate Consent - for personalization of advertising; legislation of the Russian Federation - to fulfill assigned duties. A detailed relationship between the goals, data, grounds and deadlines is given in section 6 of the Personal Data Processing Rules.

5. Unique installation identifier and registration of legal actions

5.1. The Application generates a unique installation identifier (UUID) - a random code that distinguishes one installation of the Application from another. It does not contain the name, telephone number, email address or other information directly indicating the identity of the User.

5.2. When accepting documents or changing the type of advertising, the Application transmits the relevant information to a secure server address. It is not possible for unauthorized persons to receive these records through this interface.

5.3. The unique identifier is used to link successive records of acceptance of documents and changes in advertising settings on the same installation, and not for identifying an individual.

6. Advertising and Yandex software component

6.1. For monetization, the Yandex Mobile Ads SDK is used - a software component of YANDEX LLC (hereinafter referred to as the SDK), built into the Application for downloading and displaying advertising and recording interactions with it.

6.2. The User can choose separately between personalized and non-personalized advertising. Personalization is only permitted with separate active Consent. The selected mode is transferred to the advertising SDK when the Application is launched.

6.3. In the absence or withdrawal of Consent, non-personalized advertising is displayed. For delivery, frequency capping, security, and ad event tracking purposes, the advertising SDK may continue to process a limited set of technical data.

6.4. Device coordinates are not transmitted to YANDEX LLC and advertising infrastructure participants via the advertising SDK.

6.5. The data received by the advertising SDK directly from the device is further processed by the relevant participants in the advertising infrastructure in accordance with the documents and legal grounds applicable to them.

7. Actions with data and processing methods

7.1. The Operator can collect, record, systematize, accumulate, store, clarify, extract, use, disclose to designated recipients, anonymize, block, delete and destroy personal data.

7.2. Server processing is carried out in an automated manner. Support requests can be processed in a mixed way, including processing without the use of automation tools.

7.3. Personal data are not disclosed to the general public without separate Consent to distribution or other legal basis.

8. Data recipients

8.1. To the required extent, data can be provided to:

• YANDEX LLC and participants in the advertising infrastructure - during the operation of the Yandex Mobile Ads SDK, without transmitting exact and approximate coordinates of the device;
• suppliers of server, network and technical infrastructure - for API operation, storage of technical logs, backupsssss of server systems and security;
• email providers - for receiving and considering support requests;
• authorized government bodies and other persons - in cases provided for by law.

8.2. The Rules governing delegated processing apply to server, network, technical and email service providers. They receive only the data necessary for the relevant service and are required to comply with confidentiality and security requirements. Data processing by YANDEX LLC and participants of the advertising infrastructure is carried out in accordance with the applicable contractual terms, their own documents and legal grounds.

9. Localization and cross-border transfer

9.1. The primary recording, systematization, accumulation, storage, clarification and retrieval of personal data of citizens of the Russian Federation entering the RandomSet.RU server is carried out using databases located on the territory of the Russian Federation.

9.2. The Operator does not carry out its own cross-border transfer of RandomSet.RU server data. If such a transfer is required in the future, mandatory procedures will be completed and applicable documents will be updated prior to such transfer.

10. Storage periods

10.1. Records of acceptance of documents and changes in advertising settings are kept for up to three years after the last such record of the corresponding setting or longer if this is necessary to fulfill a mandatory legal requirement or protect the rights of the Operator.

10.2. Technical logs are generally stored for no more than 90 calendar days; incident-related records are stored until the investigation and any mandatory retention period are complete.

10.3. Support requests are stored until the review is completed and, as a rule, for no more than three years after the last interaction.

10.4. Retention periods for data independently processed by the YANDEX LLC advertising SDK, app stores and operating system providers are governed by their policies.

11. User rights

11.1. The User has the right to receive information about processing, demand clarification, blocking or deletion of data in cases provided for by law, challenge the actions of the Operator, and also object to processing based on legitimate interests.

11.2. Consent to personalized advertising is revoked by changing the advertising mode in the Application settings.

11.3. General requests regarding the processing of personal data are sent to info@1294studio.ru or to the Operator's postal address and are considered in the manner established by the legislation of the Russian Federation.

12. Security

12.1. The Operator uses a secure network connection, verification of incoming data, separation of access rights, prohibition of public reading of the consent database, event logging, software updates, backups and other necessary measures.

12.2. The User is responsible for the security of their device, system account and privacy settings.

13. Minors and the nature of recommendations

13.1. The Application is intended for persons over 18 years of age. The Operator does not knowingly request information about age and does not purposefully collect personal data from persons under 18 years of age.

13.2. Where required by law, a person lacking legal capacity may use the Application and provide Consent only through a legal representative.

14. Policy amendments

14.1. The Operator has the right to update the Policy if legislation, the architecture of the Application or the composition of connected services changes. Significant changes are communicated to the User before they are applied. If the changes affect processing based on Consent, a new Consent is obtained before the relevant processing begins.

15. Contacts

Related documents

Terms of Use: https://randomset.ru/terms

Personal Data Processing Rules: https://randomset.ru/personal-data-processing-rules

Consent to the processing of personal data: https://randomset.ru/personal-data-consent

Consent to personalized advertising: https://randomset.ru/personal-ads-consent