Policy on the Processing of Personal Data
Individual Entrepreneur D. N. Pomelnikov · the game Arkev · application ru.arkev.play
This Policy sets out the procedure for the processing of personal data and the measures taken by the Operator to ensure their security, and applies to all personal data that the Operator processes in providing the game Arkev. The Policy is published for unrestricted access on the "Internet" information and telecommunications network in accordance with Article 18.1(2) of Federal Law No. 152-FZ.
1The Operator
The operator of personal data is Individual Entrepreneur Dmitry Nikolaevich Pomelnikov:
- OGRNIP 325253600040831, INN 250810935881;
- address for sending enquiries (electronic): help@arkev.ru;
- website: arkev.ru.
The Operator is entered in the register of operators carrying out the processing of personal data (notification filed with Roskomnadzor (the Russian data protection authority) in accordance with Article 22 of Federal Law No. 152-FZ).
2Key definitions
The terms "personal data", "processing", "operator", "personal data subject", "cross-border transfer", "anonymisation", "destruction" and others are used with the meanings defined in Article 3 of Federal Law No. 152-FZ. "The User" means a personal data subject who uses the game.
3Principles and legal grounds for processing
Processing is carried out on a lawful and fair basis, is limited to the achievement of specific, pre-defined and lawful purposes, and is not excessive in relation to those purposes (Article 5 of Federal Law No. 152-FZ). The legal grounds for processing (Article 6(1) of Federal Law No. 152-FZ) are:
- the conclusion and performance of a contract to which the data subject is a party — the User Agreement (the offer) on the terms of which the game is provided (arkev.ru/terms): creation and authentication of an account, login, saving progress, delivery of game content and messages;
- the fulfilment of obligations imposed on the Operator by law (Article 6(1)(2) of Federal Law No. 152-FZ) — issuing and sending the buyer a fiscal receipt for a purchase of In-Game Items made for money (Federal Law No. 54-FZ of 22 May 2003), and the accounting and tax records of such settlements;
- the data subject's consent — in cases where the processing is not covered by the performance of the contract or by another ground (for example, analytics);
- the exercise of the Operator's rights and legitimate interests, provided that the data subject's rights are not infringed — security, prevention of abuse, moderation, diagnostics.
Public information (the game name, messages displayed in the general, trade, location or clan chat) is processed with regard to Article 10.1 of Federal Law No. 152-FZ; the dissemination of such data is carried out by the User voluntarily by publishing it in the game.
4Categories of data subjects and data processed
Categories of data subjects: (1) users of the game Arkev (including potentially minors — see Section 12); (2) partners — participants in the support-a-creator programme who have entered into an agreement with the Operator on remuneration for players they have referred.
In respect of partners, the following are processed: display name (pseudonym), contact details for communication, payment details for the remuneration and information on tax status (including on the application of the professional income tax), the credentials of the partner's personal account (login and the verification value of the password), as well as information on accruals and payments. The purposes are the performance of the agreement with the partner, the calculation and payment of the remuneration and the fulfilment of the Operator's tax obligations; the grounds are the performance of a contract (Article 6(1)(5) of Federal Law No. 152-FZ) and the fulfilment of obligations imposed on the Operator by law (Article 6(1)(2)).
The Operator does not process special categories of personal data or biometric personal data, does not collect precise geolocation, the contacts in the device address book, photographs, or access to the camera/microphone. The following are processed:
| Category of data | Composition | Purpose |
|---|---|---|
| Account identifiers | internal identifier, device identifier (UUID), session token, game name (nickname) | registration, authentication, saving progress |
| External login data | the user identifier and, where the service provides one, the name: VK ID, Sber ID, Yandex ID, Google Play Games or a gaming portal (Yandex Games, VK Play, etc. — in the browser version); when logging in with an issued code — the verification value (hash) of the code | login, recovery and merging of an account |
| The buyer's e-mail address | the address indicated by the User for the fiscal receipt to be sent to; the latest such address is kept for the account so that it can be filled in at the next purchase. It may be obtained from VK ID, Sber ID or Yandex ID (where the User has granted the relevant permission) solely in order to pre-fill the field: the address is displayed to the User and may be changed by the User before payment | issuing and sending the fiscal receipt (Federal Law No. 54-FZ) |
| Order data | the fact, composition and status of an order for the purchase of In-Game Items: the pack, the amount and currency, the date, the payment identifier on the provider's side, the e-mail address the receipt was sent to | processing of purchases, support, accounting and tax records |
| User content | chat messages, mail to players, support enquiries and the correspondence on them, feedback about the game, clan names/mottos and membership applications, survey answers, name change history | communication features, moderation, support |
| Information attached to a support enquiry | the application version and installation channel, platform, server, the hero's location in the game, the device time and time zone, the game language, the screen from which the enquiry was opened, the last 20 chat lines seen by the User (including the names and messages of other users, except those blocked by the User); the hero's level, presence in the game or in the arena; for a payment enquiry — recent orders, for an appeal against a restriction — information about it; up to three screenshots of the game screen taken by the application (kept for 90 days) | technical support and handling of enquiries |
| Moderation data | reports about messages, letters and users: the reporter, the reason, the explanation, the game language, a copy of the message or letter, for a report about a user — their nickname, clan and battle at the time of the report; moderation measures (type, term and reason of a chat restriction); the list of users blocked by the User | moderation, handling of reports, community safety |
| Friends list | users added by the User as friends (up to 100); users who have added the User as a friend can see whether the User is in the game and the time of the User's last visit | communication features |
| Activity data | game events; IP address on login and registration | operation of game mechanics, analytics, security |
| Technical data | device model, OS version, application version and build, language, application distribution channel, information about the installer and the owner of updates, crash reports and performance metrics (frame timings, stutters, session duration, markers of in-game actions) | compatibility, delivery of updates, diagnostics |
| Device country and language | country code and language from the device settings, as reported by the application | selection of login methods, of the applicable version of the documents, of the interface language and of the currency |
| Analytics/advertising identifiers | the device advertising identifier (GAID) and AppMetrica analytics identifiers | measurement of installs and their sources (attribution), product analytics (Android) |
| Push notification data | the device push token issued by Google (Firebase Cloud Messaging) or RuStore; the device time zone; notification settings (kinds of notifications, quiet hours) | delivery of notifications about events in the game and of game reminders; notifications about offers and news — only with the User's consent |
5Purposes of processing
- registration, authentication and maintenance of the account, login (including via VK ID, Sber ID, Yandex ID, Google Play Games), saving and restoring progress;
- provision of game features, awarding of rewards, operation of the in-game economy;
- operation of communication features (chat, mail, clans, friends and player search) and their moderation, handling of reports from users;
- ensuring security, preventing fraud and multiple accounts;
- technical support and handling of enquiries;
- delivery of push notifications about events in the game and of game reminders — if notifications are permitted on the device; of notifications about offers and news — only with the User's consent given in the game;
- diagnostics of errors, monitoring of the stability and performance of the application, delivery of updates;
- processing of orders for the purchase of In-Game Items;
- issuing and sending the User a fiscal receipt for a settlement (Federal Law No. 54-FZ), and the accounting and tax records of such settlements;
- product analytics (in anonymised/aggregated form, where possible).
6List of operations and methods of processing
The Operator performs the following operations with personal data: collection, recording, systematisation, accumulation, storage, updating (renewal, alteration), extraction, use, transfer (provision, access), anonymisation, blocking, deletion and destruction. Processing is carried out using means of automation and without such means. The Operator does not take decisions producing legal effects solely on the basis of automated processing.
7Consent and withdrawal of consent
Where the ground for processing is consent, such consent is specific, informed, conscious and unambiguous, and relates to a defined subject matter (Article 9 of Federal Law No. 152-FZ). Starting to use the game means acceding to the User Agreement; the processing of data necessary for its performance is carried out without separate consent on the basis of Article 6(1) of Federal Law No. 152-FZ.
Consent may be withdrawn by sending an enquiry to help@arkev.ru. Following withdrawal, the Operator ceases processing and destroys the personal data within a period not exceeding 30 days, unless their retention is required on other grounds provided for by law.
8Transfer of data. Entrusting processing to third parties
The Operator may entrust the processing of personal data to other persons on the basis of a contract (an instruction) in compliance with the requirements of Article 6(3) of Federal Law No. 152-FZ; the Operator bears liability towards the data subject for the actions of such persons. Recipients/processors:
| Person | Purpose | Data |
|---|---|---|
| VKontakte LLC (VK ID) | confirmation of login | VK identifier and name; e-mail address — where the permission has been granted |
| Sberbank PJSC (Sber ID) | confirmation of login | Sber ID account identifier; e-mail address — where the permission has been granted |
| Yandex (Yandex ID) | confirmation of login | Yandex ID account identifier and name; e-mail address — where the permission has been granted |
| Google LLC (Google Play Games, USA) | confirmation of login | Google Play gaming identifier; see Section 9 |
| YooMoney NBCO LLC (YooKassa) | acceptance of payment and issuance of the fiscal receipt for a purchase of In-Game Items made for money | the composition, amount and currency of the order, the internal identifiers of the order and of the account, the User's e-mail address — for sending the receipt |
| Yandex JSC (AppMetrica) | analytics and install attribution (Android/iOS) | advertising identifier (GAID/IDFA), analytics identifiers, device data, account identifier |
| GamePush | login via a gaming portal in the browser version (arkev.ru/play) | portal authorisation data, portal player identifier and name, portal type, network identifiers |
| Google LLC (Firebase Cloud Messaging, USA) | delivery of push notifications | device push token, network identifiers; see Section 9 |
| VK Digital LLC / RuStore | delivery of push notifications; the specific service (RuStore or Firebase) is selected automatically on the device | device push token, network identifiers |
| Google LLC (Google Fonts, USA) | downloading of the fonts of the arkev.ru website when its pages are opened; in application versions 1.0.5+82 and earlier — downloading of the display font on first launch | on the website — IP address and browser information; in the application — network identifiers (IP address), device type; see Section 9 |
| Partners of the support-a-creator programme | report on referred players in the partner's personal account | game name, period of support, purchase statistics of players who have the partner's code set — entered by the player or filled in automatically after following the partner's link (until it is linked, such a code is kept in the browser — in the arkev_ref cookie — or in the app on the device for up to 30 days) |
| The Operator's monitoring system (Sentry software) | diagnostics of failures | error reports; hosted on the Operator's servers in the Russian Federation |
When the browser version of the game is opened at arkev.ru/play, the page loads the SDK of the GamePush service from the gamepush.com website. The loading takes place when the page is opened, that is, before logging in to an account, and at that moment the said service receives the IP address and information about the visitor's browser. The service is not used in the mobile application.
9Cross-border transfer
The processing of data by the following persons outside the Russian Federation constitutes a cross-border transfer (Article 12 of Federal Law No. 152-FZ):
- Google LLC (USA) — when logging in via Google Play Games (the Google Play gaming identifier, network identifiers); when delivering push notifications via Firebase Cloud Messaging (device push token, network identifiers); when downloading fonts via Google Fonts — when pages of the arkev.ru website are opened (IP address, browser information) and on first launch of application versions 1.0.5+82 and earlier (network identifiers).
Until 7 October 2026, such persons also included Shorebird, Inc. (USA) — a service through which the application received updates without being reinstalled. Since that date the Operator does not use it; however, application versions 1.0.5+82 and earlier, until the User has updated them, may still contact this service for updates on launch (information on the version and platform, network identifiers).
The Operator carries out such transfer in compliance with the requirements of Federal Law No. 152-FZ, including the filing with Roskomnadzor of a notification of the intention to carry out a cross-border transfer of personal data. The other services listed (VK ID, Sber ID, Yandex ID, YooKassa, RuStore, Yandex AppMetrica, the Operator's monitoring system) process data within the territory of the Russian Federation.
10Localisation of databases
The initial collection, recording, systematisation, accumulation, storage, updating (renewal, alteration) and extraction of the personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation (Article 18(5) of Federal Law No. 152-FZ). The game's servers and database are physically located in the Russian Federation.
11Retention periods and destruction
- Account data (identifiers, progress, user content) are processed for as long as the account exists and are destroyed when the account is deleted, with the exceptions set out below.
- Order data and the e-mail address for the receipt. These are kept with the order itself and are not destroyed together with the account: the link between the order and the account is severed, while the record itself is retained. The ground is the fulfilment of obligations imposed on the Operator by law (Article 6(1)(2) of Federal Law No. 152-FZ): the safekeeping of data necessary for the calculation and payment of taxes is ensured for no less than five years (Article 23(1)(8) of the Tax Code of the Russian Federation), and a refund receipt is sent to the same address as the original one.
- Login identifiers of a blocked account. If an account is deleted during a block in force for a breach of the User Agreement, the identifiers by means of which the login was carried out (device identifier, VK ID, Sber ID or Yandex ID identifier, Google Play gaming identifier, gaming portal identifier) are entered in a list for the prevention of re-registration circumventing the block and are stored indefinitely. The ground is the exercise of the Operator's legitimate interests, provided that the data subject's rights are not infringed (Article 6(1)(7) of Federal Law No. 152-FZ). Other data of such an account are destroyed on general terms. In addition, in the case of a permanent ban, the identifiers of the login methods linked to the account (except the device identifier) are entered in the same list immediately and are removed from it when the ban is lifted.
- Reports about the User by other users (with a copy of the message, letter or nickname at the time of the report) are kept in the moderation log even after the User's account is deleted. The ground is the exercise of the Operator's legitimate interests, provided that the data subject's rights are not infringed (Article 6(1)(7) of Federal Law No. 152-FZ): community safety.
- Screenshots attached to support enquiries are kept for 90 days and are destroyed automatically.
- Mail sent to other users remains in their inboxes; information about the sender is anonymised when the account is deleted.
- The event log (including login/registration IP addresses) is stored for a limited period — as a rule about 12 months — and is destroyed automatically.
- Upon withdrawal of consent or achievement of the purposes of processing, the data are destroyed within a period of no more than 30 days; where destruction within that period is impossible, the data are blocked and destroyed within a period of no more than 6 months (Article 21 of Federal Law No. 152-FZ).
12Processing of minors' data
The game is intended for persons aged 16 and over. Where the processing of a minor's data requires consent, such consent is given by the minor's legal representative (Article 9(6) of Federal Law No. 152-FZ). If the Operator becomes aware that a child's data have been obtained without the necessary consent, such data are deleted upon an enquiry sent to help@arkev.ru.
13Rights of the personal data subject
You have the right (Article 14 of Federal Law No. 152-FZ) to:
- obtain confirmation of the fact of processing, information on the legal grounds and purposes, on the methods of processing, on the Operator, on the composition of the data processed and the source from which they were obtained, on the retention periods, on cross-border transfer and on the persons to whom the data may be transferred;
- demand the updating, blocking or destruction of the data if they are incomplete, inaccurate, obtained unlawfully or are not necessary for the stated purpose;
- withdraw consent and demand that processing be ceased;
- appeal against the Operator's actions to Roskomnadzor or through the courts.
An enquiry is to be sent to help@arkev.ru. The Operator considers the enquiry and provides a reply within 10 working days, with the possibility of an extension of no more than 5 working days with notification of the applicant. In order to verify identity, the Operator has the right to request information confirming ownership of the account.
14Security measures
The Operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful access, destruction, alteration, blocking, copying and dissemination (Articles 18.1 and 19 of Federal Law No. 152-FZ), including: transmission of data between the application and the server over a secure connection (HTTPS/WSS); restriction and segregation of access to administrative functions; backup copying; maintaining an inventory of the data processed and minimising it. Upon establishing the fact of an unlawful transfer of personal data, the Operator notifies Roskomnadzor in the manner and within the time limits established by Article 21 of Federal Law No. 152-FZ.
15Amendments to the Policy
The Operator has the right to amend this Policy. The current version is published at arkev.ru/privacy/ru; the date of the version is stated at the beginning of the document.
16Contacts and complaints
- Operator: Individual Entrepreneur D. N. Pomelnikov, help@arkev.ru.
- The authorised body for the protection of the rights of personal data subjects is Roskomnadzor (rkn.gov.ru).
- General privacy policy: arkev.ru/privacy · User Agreement: arkev.ru/terms.