COUNTERSKY
Where to play

Personal Data Processing Policy

Revision: privacy-2026-11-12-r7-en · 12.11.2026Address: countersky.ru/en/privacy

Want to access or correct your data, delete your account or withdraw consent?

Send a request

This is a courtesy translation. In case of any discrepancy, the Russian version prevails and only the Russian version has legal force.

Individual Entrepreneur Lidiya Magomedovna Garbakova. The Countersky game and the website countersky.ru.

Version of 12.11.2026, revision privacy-2026-11-12-r7-en (translation of revision privacy-2026-11-12-r7, which replaces revisions privacy-2026-11-11, privacy-2026-11-11-r2, privacy-2026-11-11-r3, privacy-2026-11-11-r4, privacy-2026-11-11-r5 and privacy-2026-11-12-r6). Published at https://countersky.ru/privacy; this English courtesy translation is at https://countersky.ru/en/privacy.

1. General provisions

1.1. This Policy sets out what personal data the Operator processes, for what purposes, on what legal bases and for how long, to whom it is transferred, how it is protected and how a data subject can exercise their rights. The Policy has been drawn up in accordance with Part 2 of Article 18.1 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (“the Personal Data Law”) and the recommendations of Roskomnadzor on drafting an operator’s policy.

1.2. The Policy applies to personal data the Operator processes in connection with the computer game Countersky (the “Game”), its server part (api.countersky.ru) and the website countersky.ru. The Policy does not apply to third-party services, including the payment platforms RuStore and VK Play, the VK ID service and the RuStore push notification service, to the extent that they process data under their own rules as independent operators; processing on the Operator’s instruction is described in section 8.

1.3. The terms of use of the Game are set out in the User Agreement (https://countersky.ru/terms; English courtesy translation: https://countersky.ru/en/terms). The player gives consent to the processing of personal data separately in the Game interface (Consent to the Processing of Personal Data of a Countersky Player, the “Consent”).

2. Operator details

  • Operator: Individual Entrepreneur Lidiya Magomedovna Garbakova;
  • OGRNIP 326150000036988, INN 151604445785;
  • requests and personal data enquiries: via the in-Game form, via the website form https://countersky.ru/privacy/request or in writing to the postal address: 362023, Respublika Severnaya Osetiya - Alaniya, g. Vladikavkaz, p. Kartsa, ul. 9 Yanvarya, d. 49A, do vostrebovaniya (poste restante), IP Garbakovoy Lidii Magomedovne (section 12);
  • registration number in the register of personal data operators: the notification of personal data processing has been sent to Roskomnadzor; the registration number will be stated once the details are entered in the register.

2.1. The Operator personally organises the processing of personal data and is responsible for it.

3. Terms

3.1. The terms “personal data”, “processing of personal data”, “operator”, “destruction of personal data”, “cross-border transfer” and others are used in the meaning established by Article 3 of the Personal Data Law. Player (user) - an individual using the Game, including in guest mode.

4. Principles of processing

4.1. The Operator processes personal data lawfully and fairly; only for predetermined purposes; only to the extent necessary for those purposes; does not combine databases processed for incompatible purposes; ensures data accuracy and keeps data no longer than the purposes of processing require, after which it destroys the data.

5. Legal bases for processing

  • consent of the data subject (clause 1 of Part 1 of Article 6 of the Personal Data Law) - the Consent, section 1 (game account) and section 2 (support requests);
  • performance of a contract to which the data subject is a party - the User Agreement (clause 5 of Part 1 of Article 6), including for sending service push notifications (once push notifications are enabled), crediting the “Launch Gift” promotion bonus only once and keeping records of acceptance of the Agreement (purpose 1);
  • performance of obligations imposed on the Operator by law (clause 2 of Part 1 of Article 6): the Tax Code of the Russian Federation (income records), Federal Law No. 54-FZ of 22.05.2003 (cash receipts), Law of the Russian Federation No. 2300-1 of 07.02.1992 “On Consumer Rights Protection” (refunds), Articles 9, 14, 20 and 21 of the Personal Data Law (records of consents and requests);
  • the Operator’s legitimate interests - ensuring the security of the game server (clause 7 of Part 1 of Article 6), as well as the Consent, section 1.

6. Purposes, categories of data and data subjects, retention periods

6.1. Data subjects are players of the Game aged 16 or over, including in guest mode, for purposes 3 and 4, also persons who send a request via the website form or in writing, and, for purpose 5, also visitors to the website countersky.ru. The Operator does not process special categories of personal data or biometric personal data. For each purpose below, the data, legal basis and retention period are stated.

Purpose 1. Game account and game service

Creating and maintaining a game account, including a guest account, registration and login (with email and password or via VK ID), access recovery, saving game progress, accounting for in-game currency and in-game transactions; confirming the email address; crediting the “Launch Gift” promotion bonus; keeping records of acceptance of the User Agreement and consents in the Game; sending service push notifications about the cancellation or refund of payment for an in-game currency pack and about a minus on purchased Coins (Android version of the Game, once push notifications are enabled).

  • data: email address (except in guest mode); when logging in via VK ID - the VK ID user identifier; other profile data provided by LLC VK is not stored or processed; callsign or guest ID (e.g. User_12345); age stated by the player; password in transformed form, account and session identifiers, one-time password recovery code in transformed form (valid for 15 minutes); game progress of an account with email or VK ID; in-game currency balance and transaction history with separate accounting of earned and purchased currency;
  • guest mode: game progress is stored only on the player’s device and is not processed by the Operator until the player registers an account;
  • bases: the Consent (section 1), the User Agreement;
  • retention: until the account is deleted or consent is withdrawn, but no more than 3 years from the date of last activity in the account;
  • service push notifications (Android version of the Game only, once push notifications are enabled; until then no push token is generated or processed by the Operator): data - the push token issued by the RuStore push notification service for the Game on the player’s device; device platform (android); the link of the token to the account identifier or, for a guest account, to the guest ID; date and time the token was created and last updated; the Operator does not collect a separate device identifier, the advertising ID or device information; notifications are sent only about the cancellation or refund of payment for an in-game currency pack and about a minus on purchased Coins, and the Operator does not send advertising; basis - performance of the User Agreement (clause 5 of Part 1 of Article 6 of the Personal Data Law, clause 18.3 of the Agreement), no consent is required for this; transfer - the push token and the text of the notification are passed to the RuStore push notification service (clause 8.4) in the Russian Federation, no cross-border transfer takes place; retention - the token is deleted when the player logs out of the account, when the account is deleted (including after consent is withdrawn), when the RuStore service reports that the token is invalid, and no later than 3 years from the date of last activity; how to turn off - disable notifications of the Game in the device settings or do not grant permission to show them (Android 13 and later); information about the minus remains available in the Game in the “My Account” section.
  • email address confirmation: an email with a one-time confirmation link is sent from no-reply@countersky.ru via Unisender Go (clause 8.1); the link contains a random token, which is stored only in transformed form (hash), is valid for 24 hours and becomes invalid after use; whether the address has been confirmed, and the date and time of confirmation, are stored as part of the account data; legal basis and retention period - as for the account data;
  • “Launch Gift” promotion (clause 5.10 of the User Agreement): data - a hash of the normalised email address of bonus recipients computed with a secret key kept only on the server (HMAC, irreversible transformation); for normalisation, the address is converted to lower case and the part after the “+” sign in the mailbox name and, for services that do not distinguish dots in the name, also dots are disregarded; the address itself is not stored in this record and the hash is not disclosed to third parties; purpose - crediting the bonus only once (one bonus per address, including after account deletion); legal basis - performance of the User Agreement (clause 5 of Part 1 of Article 6 of the Personal Data Law, clause 5.10 of the Agreement); retention period - the hash is deleted after the promotion ends, no later than 31.01.2027, including where the account was deleted earlier;
  • “Launch Gift” promotion, login via VK ID: data - a hash of the VK ID user identifier of bonus recipients computed with the same secret key (HMAC, irreversible transformation); the identifier itself is not stored in this record and the hash is not disclosed to third parties; purpose - crediting the bonus only once (one bonus per VK ID identifier, including after account deletion); legal basis - performance of the User Agreement (clause 5 of Part 1 of Article 6 of the Personal Data Law, clause 5.10 of the Agreement); retention period - the hash is deleted after the promotion ends, no later than 31.01.2027, including where the account was deleted earlier;
  • log of acceptance of the User Agreement and consents in the Game: data - account identifier or guest ID, document (Agreement or consent), its version, action (acceptance, refusal, withdrawal), date and time according to the Game server; IP address and device information are not recorded in the log; legal basis - performance of the User Agreement (clause 5 of Part 1 of Article 6 of the Personal Data Law, clause 2.3 of the Agreement) and the Operator’s obligation to prove that consent was obtained (Part 3 of Article 9 and clause 2 of Part 1 of Article 6 of the Personal Data Law); retention period - for the term of the Agreement or consent and for 3 years after it ends; when the account is deleted, the record is anonymised (the account identifier or guest ID is removed).

Purpose 2. In-game purchases and refunds

Making and recording purchases of in-game currency packs via the payment platforms RuStore (Android version of the Game) and VK Play (Windows version of the Game), refunds, generating and sending cash receipts.

  • data: for VK Play - VK Play user identifier, IP address (to check that the country and currency of payment match), amount and currency, pack description, product identifier, order number; for RuStore - the Game passes to the RuStore Pay payment module the pack code (productId and developerPayload) and, if the player is logged in to an account with an email address, the account email address (appUserEmail) so that a cash receipt can be sent; for a guest account no address is passed; bank card data, phone number, name, VK ID identifier and session keys are not passed; the Operator receives from RuStore the invoice identifier (invoiceId), pack code and amount; for RuStore purchases, the Operator’s server stores only the account identifier, the invoice identifier (invoiceId), the pack code, the amount in roubles, the coins credited and the time of purchase; the email address, card data and phone number are not recorded in the purchase record; purchase, invoice or transaction identifiers; purchase status; date and time of purchase; for refunds to bank details - the details stated by the player in the request;
  • the Operator does not receive or store bank card data: payments are accepted by the platforms;
  • bases: the User Agreement (clause 5 of Part 1 of Article 6 of the Personal Data Law), the Consent (section 1), the obligation to use cash registers and issue cash receipts (Federal Law No. 54-FZ of 22.05.2003, clause 2 of Part 1 of Article 6), tax and consumer protection legislation; passing the email address to RuStore for the cash receipt - performance of the contract with the player (clause 5 of Part 1 of Article 6 of the Personal Data Law) and the obligation to issue a cash receipt (Federal Law No. 54-FZ of 22.05.2003, clause 2 of Part 1 of Article 6);
  • the cash receipt under Federal Law No. 54-FZ of 22.05.2003 is generated by the payment platform (RuStore, VK Play) accepting payment as the Operator’s agent; the Operator does not accept payments directly and does not use its own cash register; the receipt is sent to the User electronically to the email address specified at payment or in the account, or in the platform’s app; the platform receives the address specified by the User at payment, and if that address differs from the account address, the Operator does not receive it; fiscal data is transferred to the fiscal data operator and the Federal Tax Service of Russia by the platform;
  • retention: as for purpose 1; payment and cash receipt records - for the periods established by tax legislation (at least 5 years, subclause 8 of clause 1 of Article 23 of the Tax Code of the Russian Federation).

Purpose 3. Support requests

Considering and replying to requests from players and website visitors to Game support. Requests are accepted via the in-Game form (for players logged in to an account with an email address), via the form on the website countersky.ru (section 15), including from a guest account, and in writing to the postal address (section 12).

  • data: name stated in the request; email address; type and text of the request; game account identifier, if the request is sent from an account; for the website form - the account email address or the guest ID, the email address for the reply, the Policy revision, the revision and time of the tick box in the form; for a written request - the postal address and other information provided by the sender; records of giving consent;
  • transfer: links confirming website requests and replies are sent from no-reply@countersky.ru via Unisender Go (LLC Unisender SMART, clause 8.1) - the service receives the email address and the text of the email;
  • bases: the Consent (section 2) - a tick box in the in-Game form or, for general questions (type “Other”), in the website form; for claims and refund requests - also the User Agreement and consumer protection law; personal data enquiries and account deletion requests are processed without consent, on the basis of the Operator’s legal obligation (Article 6(1)(2), Articles 14, 20 and 21 of the Personal Data Law; purpose 4);
  • retention: requests from the in-Game form - until the purpose is achieved, but no more than 3 years from the date of the request, or until consent is withdrawn; requests from the website form - 3 years from the day of confirmation via the link (for general questions - also until consent is withdrawn), unconfirmed ones - 7 days, after which they are deleted automatically.

Purpose 4. Records of consents and data subject requests

Recording and confirming consents given and withdrawn; considering data subject requests, including withdrawal of consent and account deletion.

  • data: consent text revision; date and time of giving and withdrawing consent (the IP address and device information are not recorded; consents given in the Game are also recorded in the acceptance log, purpose 1); callsign, account identifier or guest ID; email address and content of the request; postal address - for a written request;
  • bases: Articles 9, 14, 20 and 21 of the Personal Data Law, the Consent (section 1);
  • transfer: replies to requests and links confirming website requests are sent via Unisender Go (clause 8.1) - the service receives the email address and the text of the email;
  • retention: for the period of processing for the purpose to which the consent relates and the period needed to confirm that it was obtained and withdrawn; requests sent via the website form - 3 years from the day of confirmation via the link, unconfirmed ones - 7 days, after which they are deleted automatically.

Purpose 5. Game server and website security

Protecting the game server and the website countersky.ru against unauthorised access and abuse, ensuring their operation, rate limiting of requests from a single IP address.

  • data: IP address, date and time of the request in server logs and rate-limit counters; for the website - IP address, date and time, requested page, response code, referring page address and browser information (user-agent) in web-server logs;
  • bases: the Operator’s legitimate interest (clause 7 of Part 1 of Article 6 of the Personal Data Law), for players also the Consent (section 1); for website visitors - the Operator’s legitimate interest;
  • retention: no more than 30 days.

7. Procedure and conditions of processing

7.1. Actions with personal data: collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction. Processing method: automated processing with transmission over the Internet; written requests received by post are also processed without automation (mixed processing). The Operator does not disseminate personal data (disclose it to an indefinite number of persons); the callsign may be displayed to other players in the Game.

7.2. The Operator does not make decisions producing legal consequences for a player based solely on automated processing of personal data.

7.3. Telemetry and analytics services of the Unity game engine are not used in the Game; the Game does not include Yandex Metrica or any other analytics service. The Android version of the Game requests only the INTERNET, ACCESS_NETWORK_STATE and RECEIVE_BOOT_COMPLETED permissions, as well as an AndroidX library service permission that applies only within the app itself (DYNAMIC_RECEIVER_NOT_EXPORTED_PERMISSION); permissions requiring the player’s consent (camera, microphone, location, contacts, storage) are not requested; once push notifications are enabled, the permission to show notifications (POST_NOTIFICATIONS) is added, which on Android 13 and later the player grants or refuses in the system dialog and may revoke in the device settings; the advertising ID, location and contacts are not used. Processing of data of visitors to the website countersky.ru is described in section 15.

8. Transfer and processing on the Operator’s instruction

8.1. The Operator instructs the following persons to process personal data:

  • Nadir Abdulrakibovich Anam - administration of the server and database, backups, technical support of the Game; processing takes place in the Russian Federation;
  • LLC Unisender SMART (Unisender Go service; INN 9731091240) - sending service emails (the password recovery code, links confirming the account email address, links confirming requests sent via the website form, and replies to requests and enquiries) over secure SMTP from no-reply@countersky.ru; the email address and content of the email are processed; processing takes place in the Russian Federation;
  • LLC Mnogo Prilozheniy (RuStore; OGRN 1237700094752, INN 9725113777) - under the RuStore developer agreement (clauses 4.5.1-4.5.4), processing of payment data (date, time, amount, receipt, product, crediting logs) and the player’s email address to send the cash receipt and record the payment;

8.2. The instructions are formalised by agreements containing the conditions of Part 3 of Article 6 of the Personal Data Law: the list of actions and purposes, the obligation to keep data confidential and ensure its security, and the requirements of Article 19 of the Personal Data Law. The instruction to LLC Unisender SMART is given under the Unisender Go service offer accepted by the Operator (the offer was accepted by paying for the subscription; the personal data processing instruction is contained in the offer).

8.3. The server and database are located in a data centre in Moscow with the hosting provider FirstVDS (Joint-stock company IOT (JSC IOT), OGRN 1187746221860, INN 7731399513), which provides computing capacity; it is not given access to personal data. Database backups are encrypted and stored on the server and in the hosting provider’s data centre in Moscow for no longer than 30 days; they are not stored on any other media.

8.4. LLC Mnogo Prilozheniy is also an independent operator of RuStore user data and processes it under its own policy (https://www.rustore.ru/help/legal/privacy-policy-users). RuStore payments go through payment organisations; SBP (Faster Payments System) refunds go through NCO VK Payment Solutions (OGRN 1127711000042). Bank card data, the VK ID identifier and device data are processed by RuStore and the payment organisations independently under their own rules. The RuStore SDK service libraries (metrics, crash reports) operate under RuStore’s rules; the data they process is determined by RuStore’s documentation and policy. VK Play purchase data is transmitted to and received from VK Play; VK ID login data is received from LLC VK. To this extent these persons are independent operators. Once push notifications are enabled, to send service push notifications (purpose 1) the Operator uses the RuStore push notification service provided by LLC Mnogo Prilozheniy (RuStore; OGRN 1237700094752, INN 9725113777; 125040, Moscow, Leningradsky Prospekt, 34, premises 36/1P) under the RuStore developer agreement (clause 5.10): the Operator passes the push token and the text of the notification to the service; notifications do not contain payment amounts, the email address or other account data, other than information about the refund and the minus. The push token is generated and stored by the RuStore service; delivery to the device is provided by the RuStore app or, if it is absent, by another VK ecosystem app in which the player is logged in (for example, Mail, Dzen, Odnoklassniki). Device data and data on login to these apps are processed by RuStore and LLC VK independently under their own rules. Firebase Cloud Messaging and other foreign push notification services are not used.

8.5. Personal data may be provided to public authorities in cases provided by law.

8.6. No cross-border transfer of personal data takes place.

9. Localisation

9.1. Recording, systematisation, accumulation, storage, clarification (updating, modification) and retrieval of personal data of citizens of the Russian Federation are carried out using databases located in the Russian Federation (Part 5 of Article 18 of the Personal Data Law).

10. Termination of processing and destruction of data

10.1. The Operator stops processing and destroys personal data: when the purposes of processing are achieved or the periods stated in section 6 expire; upon withdrawal of consent - within 30 days of receipt of the withdrawal; upon a request to delete an account - within 30 days of receipt of the request; upon discovery of unlawful processing - within the periods established by Article 21 of the Personal Data Law. The exception is data the Operator is required by law to keep (payment records), as well as the hashes of the email address and VK ID identifier of a “Launch Gift” promotion bonus recipient (deleted no later than 31.01.2027) and the anonymised record of the log of acceptance of the Agreement and consents (kept for the periods stated in purpose 1).

10.2. Account deletion in the Game interface is not provided. An account is deleted upon a request sent in one of the ways stated in clause 12.1; for an account with VK ID login, the request is confirmed by logging in to the account via VK ID following the Operator’s instructions; for a guest account, the request states the guest ID.

10.3. Destruction is confirmed in the manner established by Roskomnadzor Order No. 179 of 28.10.2022. Data of a deleted account disappears from all backups no later than 30 days after deletion; if data is restored from a backup, previously performed deletions are applied again.

11. Rights of the data subject

11.1. The data subject has the right to:

  • obtain information about the processing of their personal data (Article 14 of the Personal Data Law);
  • demand clarification, blocking or destruction of data if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose;
  • withdraw consent to the processing of personal data;
  • demand deletion of the game account;
  • appeal against the Operator’s actions or inaction to Roskomnadzor or in court.

11.2. Withdrawal of consent does not affect the lawfulness of processing before withdrawal or processing on other bases stated in section 5.

12. How to submit a request

12.1. Requests, withdrawal of consent and account deletion requests are sent in one of the following ways:

  • via the in-Game contact form with the request type “Personal data / account deletion” - for players logged in to an account with an email address;
  • via the form on the website https://countersky.ru/privacy/request (in English - https://countersky.ru/en/privacy/request), including for guest accounts and accounts with VK ID login (section 15);
  • in writing to the postal address: 362023, Respublika Severnaya Osetiya - Alaniya, g. Vladikavkaz, p. Kartsa, ul. 9 Yanvarya, d. 49A, do vostrebovaniya (poste restante), IP Garbakovoy Lidii Magomedovne.

The Operator considers personal data enquiries, withdrawal of consent and account deletion requests on the basis of an obligation established by law (Article 6(1)(2), Articles 14, 20 and 21 of the Personal Data Law); no consent is required for this. The tick boxes in the website form are described in clause 15.3.

The request must make it possible to identify the player and their relationship with the Operator (Article 14(3) of the Personal Data Law): it is sent from the account or states the account email address, the guest ID, the callsign or the platform order number. The Operator may ask for additional confirmation if it cannot establish that the request comes from the account holder.

12.2. The Operator replies to a request within 10 working days of receipt (Article 14(7), Article 20(1) and (3) of the Personal Data Law). A request sent via the website form is deemed received when the applicant confirms their email address via the link in the email: this is needed to establish that the request relates to the data subject (Article 14(3) of the Personal Data Law); the email with the link is sent immediately after the form is submitted. A written request is deemed received on the day the Operator receives the letter at the post office; a request from the Game is linked to the account and is deemed received when sent. The period may be extended by no more than 5 working days if the Operator sends the applicant a reasoned notice stating the reasons for the extension (Article 14(7), Article 20 of the Personal Data Law). The reply is sent from no-reply@countersky.ru via Unisender Go (clause 8.1) to the email address stated in the request, and a reply to a written request without an email address is sent to the sender’s postal address.

13. Personal data protection measures

13.1. The Operator takes the legal, organisational and technical measures provided by Articles 18.1 and 19 of the Personal Data Law, including:

  • security threats have been identified and the 4th level of personal data protection has been established in accordance with Decree of the Government of the Russian Federation No. 1119 of 01.11.2012; the requirements for this level are met;
  • a list of persons admitted to personal data has been approved; access to the database is restricted;
  • data between the Game and the server is exchanged only over secure HTTPS (TLS); passwords are stored only as a salted cryptographic hash; email addresses are stored in the database in encrypted form; session keys are stored only in transformed form;
  • the server is located in a guarded data centre in the Russian Federation; administration is carried out over SSH with key authentication; firewalling, isolation of the database from the external network, rate limiting, daily encrypted backups and automatic installation of security updates are applied;
  • an assessment of the harm that may be caused to data subjects has been carried out (Roskomnadzor Order No. 178 of 27.10.2022); internal control of compliance of processing with the law and this Policy is carried out.

13.2. If an incident resulting in unlawful transfer of personal data is detected, the Operator notifies Roskomnadzor within the periods established by Part 3.1 of Article 21 of the Personal Data Law.

14. Minors

14.1. The Game is intended for persons aged 16 or over (16+). Persons under 16 must not register in the Game or play it, including in guest mode. If the Operator learns that a player is under 16, it will destroy that player’s personal data.

15. The website countersky.ru

15.1. The website countersky.ru is the Game’s information website in Russian and English (the English version is at addresses with the /en/ prefix). The website shows pages about the Game (map screenshots, weapon cards), links to the Game’s pages on RuStore and VK Play, and a form for requests and enquiries (clause 15.3). There is no registration, subscription or mailing on the website.

15.2. No cookies or similar technologies (browser local storage, pixels, counters) are set for website visitors. Only on the service pages for moderators (/moderation), after login, a technical authorisation cookie cs_mod valid for 12 hours is used, which is necessary for the service section to work; it is not used for analytics or advertising. The website does not use Yandex services (Yandex Metrica, Yandex SmartCaptcha or others) or any other third-party analytics, advertising or bot-protection services. The language is chosen by the page address.

15.3. The form at https://countersky.ru/privacy/request (in English - https://countersky.ru/en/privacy/request) is intended for requests, personal data enquiries and account deletion requests, including for guest accounts. The form asks for the account email address or the guest ID, an email address for the reply, the request type and its text. Form data is sent to the Game server api.countersky.ru (the Operator’s server) and written to the Game server database; it is processed for purposes 3 and 4 and kept for the same periods. A request is accepted for consideration after the applicant follows the link in an email sent to the reply address immediately after the form is submitted, from no-reply@countersky.ru via the Unisender Go service (clause 8.1; the service receives the email address and the text of the email); the request is deemed received at the moment of confirmation (clause 12.2). The record stores the account email address (if stated) and the reply address (encrypted), the guest ID (if stated), the request type and text, the Policy revision, and the revision and time of the tick box (for general questions - the consent box; for personal data enquiries and account deletion requests - the confirmation box); the IP address and browser information (User-Agent) are not stored in the record. Confirmed requests are kept for 3 years from the day of confirmation and unconfirmed ones for 7 days, after which they are deleted automatically. Correspondence on the request and internal notes are kept together with it and deleted within the same period. To protect against spam, the Operator itself limits the submission rate from one IP address (purpose 5; the hashes used for this are deleted after 2 days) and uses a hidden form field; no cookies or third-party services are used for this. One tick box is mandatory to submit the form, and its text depends on the request type: for general questions (type “Other”) - a box giving consent to the processing of the data entered in the form to review and answer the request under section 2 of the Consent (version support-2026-11-11-r8), the basis for processing being consent; for personal data enquiries and account deletion requests - a box confirming that the visitor is entering their own data and has read how it will be processed to answer the request (section 12); this box is not consent, and the basis for processing is the Operator’s legal obligation (Article 6(1)(2), Articles 14, 20 and 21 of the Personal Data Law). A separate box “I have read the Policy” is also ticked.

15.4. Without submitting the form, visiting the website involves processing only the IP address and request information in web-server logs (purpose 5). It is used to ensure the operation and security of the website, kept for no more than 30 days and then deleted automatically. The website is hosted on the same virtual server as the Game server (api.countersky.ru), with the hosting provider FirstVDS in a data centre in Moscow (clause 8.3); no resources from third-party domains are loaded on the website. Web-server log data is not combined with game account data, and the Operator does not use it to identify visitors. No cross-border transfer takes place.

15.5. If analytics, cookies other than strictly necessary technical ones, or other third-party services are added to the website, the Operator will update the Policy and request visitors’ consent, where required by law, before enabling them.

15.6. The User Agreement is available at https://countersky.ru/terms (courtesy translation: https://countersky.ru/en/terms); the archive of its versions is at https://countersky.ru/terms/archive and https://countersky.ru/en/terms/archive. The rights of website visitors and how to submit requests are set out in sections 11 and 12.

16. Final provisions

16.1. The Policy is publicly available and published at https://countersky.ru/privacy (English courtesy translation: https://countersky.ru/en/privacy); a link to it is available in the Game.

16.2. The Operator may amend the Policy. A new version takes effect upon publication unless otherwise stated in it. Previous versions are kept by the Operator and provided upon request. Amending the Policy does not replace obtaining new consent where required by law.

16.3. Questions about the Policy are sent in the ways stated in clause 12.1.

User AgreementPersonal data request