Personal Data Consent
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测试版草稿。标有 [FILL IN] 的信息尚未确定,将在正式发布前补全。
This is a separate consent document. Users in Russia give it in addition to accepting the Terms of Service and the Privacy Policy, as required by Federal Law No. 152-FZ "On Personal Data". It also serves as consent under the Law of the Republic of Kazakhstan "On Personal Data and Their Protection". You give it by ticking a separate checkbox when you create an account; we record the date and the version of this document. We determine the country from the IP address; when it cannot be determined, we ask for this consent too.
Who gives consent and to whom
I, the user who creates an account on AI Game Platform (identified by the email address or external account used for sign-in), freely, of my own will and in my own interest, give my consent to [FILL IN: legal entity name], BIN [FILL IN: BIN], located at [FILL IN: registered address] (the "Operator"), to process my personal data on the terms below. If I am under 14, this consent is given by my parent or guardian.
Purposes
- creating and maintaining my account and signing me in;
- providing the Platform's features: playing games, matches, parties, text and voice chat, profiles, follows, likes, comments, publishing games and AI tools for authors;
- applying age-based restrictions;
- moderation, safety, preventing fraud and abuse;
- ranking games and showing my feed under the Recommendation Rules;
- aggregated statistics for game authors;
- sending sign-in codes and messages about my account and changes to the documents;
- complying with the law.
Personal data covered
Email address; date of birth; nickname, display name, avatar, bio and link; the identifier of an external sign-in account (Google, Apple, VK ID, Yandex ID) and the email it shares; language and settings; content I create (games, prompts, attachments, dictated audio, comments, chat messages); my likes, follows, blocks and reports; play sessions and match results; IP address, approximate country, browser and device type; records of accepted document versions and, for a child under 14, of parental consent.
Actions with the data
Collection, recording, systematisation, accumulation, storage, clarification (updating, changing), extraction, use, transfer (provision and access), blocking, deletion and destruction, with and without automation tools.
Making data public
The nickname, display name, avatar, public profile fields, published games and comments are visible to other users and may be indexed by search engines, because publishing them is the purpose of those features. Date of birth and email are never public.
Third parties that process data on the Operator's instructions
- a hosting provider in the Russian Federation — the server where data of users in Russia is first recorded;
- DigitalOcean (USA) — hosting of the main servers in [FILL IN: country of the main data centre];
- Resend (USA) — delivery of email;
- OpenAI (USA) — AI generation, speech recognition and text moderation;
- Cloudflare (USA) — network services for the domains where games run;
- the sign-in provider I choose (Google or Apple, USA; VK or Yandex, Russia).
Cross-border transfer
If I am located in Russia, my personal data is first collected, recorded, systematised, accumulated, stored, clarified and extracted in a database on a server in the Russian Federation, and only then copied to the Operator's main servers. I understand and agree to this cross-border transfer: to the Republic of Kazakhstan, where the Operator is located (a party to Council of Europe Convention 108, a country providing adequate protection of personal data), to the country of the main data centre ([FILL IN: country of the main data centre]), and to the processors listed above, including in the USA, which may not be considered to provide adequate protection. The Operator notifies Roskomnadzor of the processing and of the cross-border transfer (registry of operators number: [FILL IN: Roskomnadzor operator registry number]).
Term and withdrawal
This consent is valid until my account is deleted, or until I withdraw it. I can withdraw it by deleting my account in settings or by writing to [FILL IN: personal data requests email]. After withdrawal the Operator stops processing and destroys the data within 30 days, unless the law allows or requires it to keep certain data (for example, records of moderation and legal requests). I understand that without this consent the Operator cannot provide me with an account.