This Policy describes how the Frolick operator processes personal data in connection with the Service, including in situations subject to Russian Federal Law No. 152-FZ “On personal data”. The operator is self-employed Ulyana Vladimirovna Stepanova, INN (TIN) 544052568288. OGRN/OGRNIP does not apply to this self-employment status. For personal data matters, contact us via the form on the Contact page (/contact). Operator details also appear in section 10 of the public offer.
2. Purposes of processing
We process personal data to register and authenticate users, provide games and content features, process payments, support users, improve the Service, comply with law, and send notices where permitted.
3. Categories of data subjects and data
Subjects include registered users, site visitors, and in some cases minors using the Service through schools. Data may include identifiers (username, email), technical data (IP, device, cookies), usage data, payment-related data handled by payment providers, and content you upload.
4. Legal grounds
Processing may be based on consent, performance of a contract, legal obligation, or legitimate interest, as applicable. Where consent is required, you may withdraw it without affecting prior lawful processing.
5. Processing procedures and storage
We collect, record, systematise, accumulate, store, clarify, use, transfer (including cross-border where applicable), depersonalise, block, and delete data as needed for the stated purposes. Storage periods follow legal requirements and operational necessity unless a shorter period is agreed.
6. Security measures
We apply organisational and technical measures appropriate to the threats, including access control, encryption where appropriate, logging, and vendor management.
7. Rights of data subjects
You may request access, clarification, blocking, or deletion where applicable, and object to processing based on legitimate interest. Requests should be sent to the operator’s contact. You may also lodge a complaint with your supervisory authority where applicable.
8. Updates
We may update this Policy. The current version is published on the website with the “last updated” date.
