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Data Processing Agreement

Version of 22 October 2026

This is a translation for convenience. In case of any discrepancy the Russian version prevails.

This Data Processing Agreement (“DPA”) is part of the Terms of Service between the User (“Controller”, “Client”) and Individual Entrepreneur Grigoriy Vladimirovich Yatsunov (tax id 362083037805 (OGRNIP 326366800037471), “Processor”).

1. Roles

The Client is the controller of its players’ data and decides whether to use the SDK, which events to send and whether player consent is required. The Processor processes player data only on the Client’s documented instructions (the Service settings, the Terms and this DPA).

2. Subject matter

Data subjectsPlayers of the Client’s games
DataAnonymous player id, device and environment data, country (from IP without storing the IP), game events; optionally a user id chosen by the Client
OperationsCollection, storage, aggregation, reporting, anonymisation, deletion
PurposesGame analytics for the Client; anonymised aggregated statistics (section 5)
DurationThe retention period of the Client’s plan

3. Processor obligations

4. Client obligations

Have a legal basis, inform players, do not send direct identifiers or special categories of data, and initialise the SDK after consent where consent is required.

5. Anonymised aggregated statistics

The Client instructs and permits the Processor to anonymise game data and produce aggregated statistics for industry benchmarks (shown to all users) and market analysis, only for groups of at least 5 games from at least 3 studios with at least 100 players each, keeping aggregates only (quantiles) without identifiers of games, studios or players. Such statistics are not personal data.

6. Sub-processors

General authorisation: hosting provider (servers in Russia) and an e-mail provider (e-mails to Service users only). Changes are published on this page.

7. Deletion and international transfers

Player data is deleted within 60 days after the retention period, game deletion or termination. Data of EU players is processed in Russia; where GDPR applies, the Client assesses the transfer, and the parties may sign Standard Contractual Clauses on request. Lawyer: review this section for EU players. Contact: info@redrockstudio.ru.