This is a courtesy translation of the Russian-language document required by Article 18.1 of Russian Federal Law No. 152-FZ. In case of any discrepancy, the Russian version prevails. For a plain explanation of the same practices, see the Privacy Policy.
The personal data operator is the person identified in the “Rightholder” section of this page. Address for data subject requests: support@quickleron.online.
Category of data subjects: users of the Game (individuals).
Personal data processed:
The Operator does not retain: surname, given name and patronymic; usernames and profile photographs from external services; telephone number; email address (except where the subject writes to us); residential address; precise location data; payment credentials.
If the distributing platform passes a name when the Game is launched, it is used only to build the initial public name when the account is created. Only that result is written to the Operator’s information system; the source name is not stored as a separate field in the database or logs.
The Operator does not process special categories of personal data (Article 10 of 152-FZ) or biometric personal data (Article 11).
5.1. Processing is carried out using automation. Operations performed: collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer (provision, access), blocking, deletion and destruction.
5.2. Personal data are obtained from the data subject (including via the distributing platform when the Game is launched) and generated through use of the Game.
5.3. The Operator does not process personal data to promote third-party goods, works or services, and does not transfer data to third parties for such purposes.
5.4. The Operator entrusts processing to third parties under agreements imposing confidentiality and data protection obligations (Article 6(3) of 152-FZ). Categories of such parties: a hosting provider (servers and database), a content delivery network operator, a software error monitoring service, web analytics services, and the platforms distributing the Game. Details of the specific parties are provided to the data subject and to the competent authority on request sent to the address in section 1.
5.5. Display to other users. Inside the Game, other users see: the public name (pseudonym), the hero skin, the level, round results and — unless the user has hidden it in settings — the two-letter country code. Nothing else is shown: surname, given name, username and profile photograph are not retained by the Operator at all (section 4). The public name is chosen and can be changed at any time by the user; the Terms of Use prohibit including contact details or information about identifiable individuals in it. Display of the public name and results in ratings is a condition of the Game’s competitive modes; on request to the address in section 1 the public name is replaced with an automatic pseudonym.
6.1. The information system applies an automated assessment of indicators of automation software (auto-clickers, scripts) based on game input characteristics. As a result, an account may be excluded from public ratings and competitive matchmaking, and the intensity of its use of the Game may be technically limited. These consequences do not deprive the user of access to the Game, do not affect purchased paid features, and produce no legal effects.
6.2. The automated in-game measures in clause 6.1 do not produce legal effects, terminate access to the Game or cancel purchased paid features. Suspension or termination of access and cancellation of a paid entitlement are not imposed on the basis of solely automated processing: the Operator makes such a decision with human involvement.
6.3. The Operator does not disclose the indicators, thresholds or assessment methods: disclosure would render the Game’s protection pointless.
6.4. The data subject may contact the Operator at support@quickleron.online under Articles 14, 20 and 21 of 152-FZ, and — if located in the European Economic Area — may object to processing carried out on the basis of legitimate interests (Article 21 of Regulation (EU) 2016/679). A possible error in an automated measure may be sent to the Operator for review; this does not require disclosure of security indicators, thresholds or source code.
7.1. Core processing infrastructure is located in the Federal Republic of Germany (European Union). The Operator is located in the Russian Federation. Some Platforms and processors may use infrastructure in the European Economic Area, the United Kingdom and the United States of America.
7.2. When collecting Russian citizens’ data, account identity details (the Platform, chat and Game identifiers, public name, language and country) are recorded and updated in a separate database in Russia. Core gameplay data are then processed in the core infrastructure stated in clause 7.1. Article 18(5) of 152-FZ applies to the scope and sequence of operations; any later cross-border transfer must meet Article 12.1.
7.3. Before a transfer governed by EU or UK GDPR starts, the Operator must determine and put in place a mechanism permitted for that flow and the necessary contractual and technical safeguards. Narrow derogations for individual necessary operations are not relied on for bulk, repetitive transfers. Information about the mechanism actually used and an available copy of safeguards are supplied on request.
8.1. Personal data are processed until the purposes of processing are achieved and for the periods established by law.
8.2. The Account and related data are normally deleted within 30 days of a request, unless a shorter period applies to the particular ground or law requires selected records to remain. Payment records are retained for the periods required by applicable accounting, tax and other law; Russian accounting records are generally retained for at least five years.
8.3. Detailed round history is retained, as a rule, for no longer than 180 days, competitive-mode records for no longer than 12 months, technical logs for no longer than 60 days, and bot-screening data for no longer than 30 days, after which they are destroyed or anonymised. Records of documents accepted and consents given are retained until the account is deleted, as evidence of acceptance.
8.4. Where the purposes are achieved, consent is withdrawn (if processing was based on it), or unlawful processing is identified, the data are destroyed within the periods set by Articles 5, 9 and 21 of 152-FZ.
The data subject has the right to obtain information concerning the processing of their personal data (Article 14 of 152-FZ); to require rectification, blocking or destruction of data that are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose; to withdraw consent; and to appeal the Operator’s actions to Roskomnadzor or in court.
Requests should be sent to support@quickleron.online and must allow the account to be identified (writing to support from the same platform account is sufficient). Processing information is supplied within 10 working days, extendable by no more than five working days with a reasoned notice. The specific periods in Articles 20 and 21 of 152-FZ apply to correction, restriction, cessation and destruction.
The Operator applies the measures actually required under Articles 18.1 and 19 of 152-FZ: publishing this Policy, restricting and segregating access to information systems, encrypting data transmission channels, maintaining backups, restricting and logging administrative access to servers, and minimising the data processed. Organisational and technical measures are reviewed when the system or risks change and are not publicly disclosed where doing so could weaken security.
The Operator may amend this Policy. The current version, with its number and effective date, is published at https://quickleron.online/legal/pd.
Evgenii Nikolaevich Manatskii (Манацкий Евгений Николаевич), Individual entrepreneur (sole proprietor), Russian Federation
Tax ID: 615433067600 · Registration No.: 315615400008286
Registered on 21.07.2015, registering authority: Interdistrict Inspectorate of the Federal Tax Service No. 28 for Rostov Region
apt. 27, 171-2 Dzerzhinskogo street, Taganrog, Rostov region, 347924, Russia
Contacts: support@quickleron.online, @QuickleronBOT