ARKEV. We're on VK ← General Policy

Policy on the Processing of Personal Data

Individual Entrepreneur D. N. Pomelnikov · the game Arkev · application ru.arkev.play

Version of 7 October 2026 · drawn up in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data"

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:

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:

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 dataCompositionPurpose
Account identifiersinternal identifier, device identifier (UUID), session token, game name (nickname)registration, authentication, saving progress
External login datathe 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 codelogin, recovery and merging of an account
The buyer's e-mail addressthe 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 paymentissuing and sending the fiscal receipt (Federal Law No. 54-FZ)
Order datathe 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 toprocessing of purchases, support, accounting and tax records
User contentchat 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 historycommunication features, moderation, support
Information attached to a support enquirythe 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 datareports 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 Usermoderation, handling of reports, community safety
Friends listusers 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 visitcommunication features
Activity datagame events; IP address on login and registrationoperation of game mechanics, analytics, security
Technical datadevice 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 languagecountry code and language from the device settings, as reported by the applicationselection of login methods, of the applicable version of the documents, of the interface language and of the currency
Analytics/advertising identifiersthe device advertising identifier (GAID) and AppMetrica analytics identifiersmeasurement of installs and their sources (attribution), product analytics (Android)
Push notification datathe 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

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:

PersonPurposeData
VKontakte LLC (VK ID)confirmation of loginVK identifier and name; e-mail address — where the permission has been granted
Sberbank PJSC (Sber ID)confirmation of loginSber ID account identifier; e-mail address — where the permission has been granted
Yandex (Yandex ID)confirmation of loginYandex ID account identifier and name; e-mail address — where the permission has been granted
Google LLC (Google Play Games, USA)confirmation of loginGoogle 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 moneythe 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
GamePushlogin 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 notificationsdevice push token, network identifiers; see Section 9
VK Digital LLC / RuStoredelivery of push notifications; the specific service (RuStore or Firebase) is selected automatically on the devicedevice 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 launchon 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 programmereport on referred players in the partner's personal accountgame 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 failureserror 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):

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

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:

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