Privacy Policy

Version 1.0, 16 August 2026.

1. General provisions

1.1. Operator

The operator of personal data is Vitaly Vitalyevich Karimov (the "Operator"). Contact for any questions about data: privacy@eskoper.ru.

1.2. Scope

This policy applies to the mobile game Pawnook: Triple Tile Match (published in Russian as «Лапкино: Плитки три в ряд», package com.vkarimoff.fruitcafe) for Android, distributed through Google Play, RuStore and other app stores (the "Game").

1.3. Categories of data subjects

The Operator processes data of players and of people who contact support.

1.4. Key terms

The terms "personal data", "processing of personal data", "operator" and "cross-border transfer" are used with the meanings given to them by Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" of the Russian Federation.

"Installation identifier" means a random number that the Game creates on the device at first launch. It is not linked to a name, phone number, email address or account, and it disappears when the Game is uninstalled.

1.5. Changes to this policy

The current version is published at https://eskoper.ru/privacy/lapkino/en/, stating its version number and date.

2. Purposes of processing

3. Legal grounds for processing

1. Consent of the data subject (Article 6(1)(1) of Law No. 152-FZ) — purposes 2.3 and 2.4. Consent is given by a separate action at first launch and may be withdrawn (Section 8).
2. Performance of an agreement with the user (Article 6(1)(5)) — purposes 2.1, 2.2 and support: without processing technical data about the device the Game cannot be launched or its progress saved.
3. Legitimate interests of the Operator (Article 6(1)(7)) — protecting the Game from fraud and abuse.
4. Compliance with obligations imposed by law (Article 6(1)(2)).
5. Prior consent of the data subject (Article 15(1) of Law No. 152-FZ) — personalised advertising (Section 7).

Consent is voluntary: without it the Game still works and advertising is non-personalised. Events that occur before consent is confirmed are stored on the device and transmitted only afterwards.

4. What data is processed

4.1. Data you provide yourself

No registration is required: the Game does not create an account and does not ask for a name, email address or phone number. If you contact support, we process the text of your message and the address it was sent from.

4.2. Data collected automatically

The Operator does not process special categories of personal data or biometric personal data.

5. Procedure and conditions of processing

5.1. Methods of processing

Processing is carried out both with and without the use of automation means. Progress, settings and the installation identifier are stored on the device and are deleted together with the Game.

5.2. Where data is processed

The databases in which personal data of citizens of the Russian Federation is collected, recorded, systematised, accumulated, stored, updated and retrieved are located in the Russian Federation.

5.3. Security measures

The Operator applies the legal, organisational and technical measures required by Articles 18.1 and 19 of Law No. 152-FZ: it limits the data collected to the purposes in Section 2, uses a pseudonymous identifier instead of a name or contact details, transmits data over secure channels and restricts access to it.

5.4. Retention periods

Data is kept no longer than the purposes in Section 2 require and no longer than the periods set by law. Data on the device is kept until the Game is uninstalled.

When consent is withdrawn, processing for the relevant purposes stops and the data is destroyed within no more than 30 days, unless the Operator is entitled to continue processing on another ground.

Anonymised and aggregate metrics are not personal data: the Operator may store, use and disclose them without limits on period or scope.

6. Transfer of data to third parties

The Operator entrusts the processing of personal data to the parties listed below, and also to contractors, consultants and partners engaged to develop, maintain, analyse and promote the Game — to the extent required for the purposes in Section 2 and under confidentiality obligations. Data is transferred to others in cases provided for by law, and in the event that rights to the Game are transferred to another party, which then assumes the obligations under this policy.

Ads are selected by Yandex mediation, which engages partner ad networks: their software modules run inside the Game and receive the advertising identifier and technical data about the device. Which networks these are is decided by Yandex and may change without an update to the Game.

6.1. Cross-border transfer

Data processed for analytics purposes does not leave the Russian Federation. Advertising is the exception: Google LLC (USA) and partner ad networks may be located outside Russia and receive the advertising identifier and technical data about the device. The USA is not on the list of states providing adequate protection of the rights of personal data subjects; this transfer is carried out on the basis of the player's consent.

7. Advertising

Ads in the Game are selected and displayed by the Yandex advertising network. If advertising is shown before consent is confirmed, it is non-personalised.

You can opt out of personalisation at any time through your operating system by resetting or deleting the advertising identifier. Withdrawing consent (Section 8) also stops personalisation; advertising continues to be shown.

8. Player rights and how to make a request

8.1. Rights

A player has the right to obtain confirmation that their data is being processed and the information listed in Article 14(7) of Law No. 152-FZ; to demand that data be corrected, blocked or destroyed; to withdraw consent; to object to processing for the purposes of promoting goods, works and services; and to appeal the Operator's actions to Roskomnadzor or to a court.

8.2. How to send a request

Send your request to privacy@eskoper.ru. Under Article 14(3) of Law No. 152-FZ it must contain details of the identity document of the applicant or their representative; information confirming that the Operator processes the applicant's data — usually the installation identifier; and the applicant's signature. The request may be sent electronically.

The Operator responds within the period set by law — 10 working days from receipt, extendable by no more than 5 working days.

8.3. Withdrawal of consent and deletion of data

Send a withdrawal of consent to privacy@eskoper.ru in free form. You can also stop data collection yourself by uninstalling the Game or clearing its data through the operating system: the installation identifier disappears with it.

8.4. Installation identifier

The installation identifier is shown in the Game's settings — you can attach it to your request.

9. Data of minors

The Game is not directed at children. Processing of a minor's personal data is permitted with the consent of their parent or other legal representative; enquiries are accepted at privacy@eskoper.ru.

10. Players in the European Economic Area and the United Kingdom

For players in the EEA and the United Kingdom the grounds for processing are consent (Article 6(1)(a) GDPR), performance of a contract (Article 6(1)(b)) and legitimate interests (Article 6(1)(f)). Such players have the right to request access to their data, its rectification, erasure, restriction of processing and portability, to object to processing, and to lodge a complaint with the supervisory authority in their country of residence.

11. Contact

For any questions relating to the processing of personal data: privacy@eskoper.ru.