Privacy Policy regarding personal user data

Effective date: May 26, 2018
of the new edition of November 28, 2023

This Online Privacy Policy (hereinafter referred to as «Policy») is a document developed by our company, PROJECT FIRST LLC, in accordance with the legislation of  the Russian Federation, legal address: 1st Spasonalivkovsky str. 19-14, Moscow, Russian Federation, 119049 (hereinafter referred to as «We» or «Our») for users of our Products (hereinafter users of our products referred to as «You» or «Your») to facilitate understanding in what ways We collect, how we process, use, disclose and manage Your Personal data and what rights You have when We collect and process Your Personal Data.

We operate Applications and Games as defined herein which are oriented for children. This Policy is designated to provide You, the legal guardian of children under the age of 13 (thirteen) years – for the United States, children under the age of 16 (sixteen) years for the EU member states unless a member state has set a different age limit, and etc., with guidance regarding our privacy practices and principles with respect to collecting, using and disclosing Personal Data regarding children under the specified age (“Kids”) that are using our Applications and Games. We also have Products’ features and Website designated for adults only which may collect Personal Data pertaining to You (collecting, using and disclosing of such Personal Data that is also covered by this Policy). 




  1. Terms and Definitions

The term «Application» within the framework of this Policy means software developed by us and performing a certain function directly for the user of the software.

The term «Products» within the framework of this Policy means our Games and Applications and Website that we have developed or any other digital products produced/provided by us.

The term «Game» within the framework of this Policy means the Game, which is also an Application, developed by us.

The term «Website» within the framework of this Policy means the platform(s) that We directly control and through which We may offer You additional Game functionality and/or provide general information about the Products. 

The term «Users» within the framework of this Policy means individuals (adults and Kids as defined herein) who use the Application and/or the Game in any way or use our Services/Products.

The term «Services» in this Policy applies to Games, Applications, Website and other digital products developed by us, and their properties that we directly control.

The term «Personal Information/Personal Data» in this Policy means information collected by us for the purpose of supporting internal operations information, which includes combined definitions of personal information from the relevant codes and acts (see the list of laws and regulations below). We treat any information relating to an identified or identifiable data subject as personal to the broadest extent. It includes, but not limited to, the information that identifies, relates to, describes, is capable of being associated with, or may reasonably be linked, directly or indirectly, with a particular consumer or household. We also treat pseudonymous data and depersonalized identifiers as Personal Information, if they allow in combination to establish a link between such information and a patricidal consumer, or household, or if they can be used to recognize a user over time and across different websites or online services. 

For the purposes of this Policy:
the term «Game Instance Id» means a unique alphanumeric code (identifier), assigned automatically to each User in a particular Game.
the term «App Set ID» means a unique alphanumeric code (identifier), assigned automatically to each User in Google Play.
the term «IDFV» means a unique alphanumeric code (identifier), assigned automatically to Us (as a developer) in the iOS system for the one particular device.
the term «FID» means a unique alphanumeric code (identifier), assigned automatically to Us (as a developer) within the Firebase platform exploitation for one particular device.
the term «Android ID» means a unique alphanumeric code (identifier) assigned automatically to each User and its signature application key for the one particular device in a particular Game.
All the terms above collectively are called «Identifiers» for the purposes of this Policy.


  1. General Provisions

We strive to protect the confidentiality of your Personal Data that we collect and process. During data processing, we undertake to take all necessary measures in strict accordance with applicable law and exclusively on legal grounds that allow such collection and processing.We do not knowingly collect any personal information from Kids other than as expressly specified herein. Some of our Products, specifically Websites, are strictly designated for adults and may be accessed only by them. 

We also age-gated some of the features in our Games, so that they are not available for use by Kids. The age gate is being conducted when the User tries to access some sections of the Game which are not intended for Kids, specifically, the authorization feature after passing which User can access broader functionalities of the Game. For avoidance of doubt, Games can be freely used and give a great Game experience without exploitation of functionalities that require adult involvement.

All our Websites, as well as Games and Applications available for use on mobile devices, to the extent that they are related to the collecting, processing and protecting your Personal Data, as well as Personal Data pertaining to Kids, are governed by this Policy. Thus, by using any of our Products and/or Services, you agree to this Policy.

Also, if you do not agree with the provisions of this Policy, you must stop using our Products and/or Services and delete the Application and/or the Game from all your devices.

When We collect your Personal Data and determine the purposes and methods for which this data is collected and used, we become a «Data Controller» for the purpose of complying with the provisions of the EU General Data Protection Regulation («GDPR») and any other European legislation on personal data protection. We may also be a «Data Operator» in accordance with the Children’s Online Privacy and Protection Act of 1998 («COPPA»).

Your Personal Data is processed by Personal Data Processors — persons who process your Personal Data in our name (on our behalf) for our purposes. The data processors/persons who process your Personal Data are listed in clause 6 and information about the information they collect is given in clause 5 hereof.  

Regarding the use of your Personal Data, we comply with the provisions and requirements of the following laws and regulations:

      • EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 On the protection of natural individuals with regard to the processing of personal data and on the free movement of such data, as well as on the repeal of Directive 95/46/EC General Regulation on the Protection of Personal Data (EU) (further — «GDPR»);
      • GDPR — Children;
      • Children’s Online Privacy Protection Act abbreviated as «COPPA»- the American federal law on privacy which entered into force on April 21, 2000;
      • CCPA — California Consumer Privacy Act, a law on the protection of personal data of users of the state of California which entered into force on January 1, 2020;
      • Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data (Strasbourg, 28 January 1981);
      • Federal Law of the Russian Federation «On Personal Data» (No. 152-FZ) which became effective on July 27, 2006.

Among other things, we follow the rules for Product developers established by the Google Play and Apple App Store online application stores (“Platforms’ rules”). The texts of these rules are listed below:


We do not use APIs and SDKs not approved for Kid’s applications for authentication and authorization. Any authorization, necessary for the using of Our services, may be available and accessed solely by adults.


  1. Information We Collect

3.1. Information about the Kids. We can collect two types of information pertaining to Kids: 

3.1.1.  Non-identifiable Kid’s information. We may collect non-identifiable and anonymous information as detailed below (“Kids Non-identifiable Information”). Kids Non-identifiable Information may also include technical information such as: type of operating system, type of browser, screen resolution, User session ID, time zone, session start / stop time, source of traffic, device type, performance errors and problems, Kid’s gameplay, gaming success. We may collect non-identifiable and anonymous information as detailed below (“Kids Non-identifiable Information”). Kids Non-identifiable Information may also include technical information such as: Kid’s gameplay, gaming success.

3.1.2. Kid’s Age, Identifiers and no other Kids personal identifiable information. We may collect the information under Kid’s age (as a classification characteristic), and/or a device identifier number («Identifiers», see Terms and definitions), and/or the Internet Protocol address («IP address»).

We do not collect from Kids any information that may personally identify an individual (, address, e-mail) (other than Identifiers which is collected for the limited purposes specified in section 5  of this Policy such as supporting the internal operations of the Products and for maintaining the proper functioning of the Games) and any other personally identifiable information of a private and/or sensitive nature about the Kids. 

We do not link any collected non-identifiable information to the Kids’ Identifiers. 

3.1.3. We may also collect Personal (Identifiable) Information about Kids that parents, legal representatives (adults) voluntarily provide in our Applications. However, such additional information is not required for Games functioning and we will not specifically require adults to provide such information. 

3.2. Information about the adult. We can collect  three types of information.

3.2.1. Information necessary to provide you with the technical assistance you requested. The first is the information provided by you when you contact us electronically or in writing in order to obtain technical support. This information may include: information about your name, email address, device type as well as any other information that you voluntarily provide to us. This information is used by us solely for the purpose of providing you with technical support and for contacting you, and only for the time of providing you with assistance and replying to you. We do not store this information.

We may also collect your Game Instance Id in cases when you contact our support service using the email client on your device. When contacting us by sending letters through your email client, you also provide us with information about your email address, which is information that allows us to identify you. Therefore, by sending us emails, you automatically agree to provide us information about your Game Instance Id as well as your email address.

3.2.2. Non-identifiable Adult’s information. The second type of information is non-identifiable information about your use of Applications that does not directly identify you and is collected by us solely to help us improve the quality of our Products and/or Services or for other purposes as described in section 5 of this Policy. Such information includes technical information (type of operating system, type of browser, screen resolution, User session ID, time zone, session start / stop time, source of traffic, device type, performance errors and problems) which may be collected through any of the Products, including adults targeted Website.

3.2.3. Personal (Identifiable) Information. Personal (Identifiable) Information may be collected from adult User during authorization (if any is integrated into the Games and Applications) that adult User may pass in our Application (such Personal Information includes email address), through the Website use or making in-app purchases (if applicable) (such Personal Information may include identifiers, information which is collected through cookies, web-beacons and other tracking technologies, transaction information, payment details). Personal (Identifiable) information may also include any other information you provide through any of the Products. Authorization is available for adults in the settings section and age-gated as well as any features connected with making in-app purchases.


  1. Information collected by third parties

Please note that, if you accept this Policy, the following data is collected automatically by third parties in connection with your use of Our Products — by Processors in accordance with the applicable laws:

  • Information about your use of our Products/Services: data about the gameplay and your interactions with other players (if applicable), your gaming success data;
  • Your IP address and mobile device IDs (for example, device ID);
  • Your device data such as the device name and operating system, browser type and language;
  • IP based general location data (up to the definition of the city/region, etc.). 

We do not allow behavioral targeting ads in our Kids; directed Applications (We do not use personalized ads). We strive that all of our partners (including advertising, analytical, payment services and others) adhere to the same standards for the collection, usage and disclosure of Kid’s data as We do, but We cannot be responsible if they breach the commitments they gave to us regarding the collection of information. In case of such breaches, You agree that our liability is limited to the amounts We are able to receive as indemnification for the breaches from our partners. 


  1. The Purposes of Processing (Collecting) Personal Data

We collect your Personal Data for some or all of the following reasons:

5.1. to provide You with Products and Services in accordance with the terms defined in the User Agreement;

5.2. to provide You with information about our Products and Services, if You have given your consent to receive them;

5.3. to improve the gaming experience, taking into account the individual requirements of the particular User, to ensure the best quality of our Products or Services as well as to ensure the functionality and support of our internal operations.

5.4. fulfilling a User’s requests as specified in clause 3.2.1;

5.5. ensuring legal or regulatory compliance;

5.6. serving advertisements (for Kid’s directed Games and Application We use only advertisement suitable for Kids’ audiences);

5.7. protecting the security or integrity of Users and Products; 

5.8. authenticating purchases made by Users (adults).


  1. The legal basis of Processing (Collecting) Personal Data:

6.1. Contractual Necessity. This covers information that is processed by us in order to provide you and the Kid with Services that are expected.

6.2. Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your and Kid’s use of our Services to pursue our legitimate interests in order to ensure you and the Kid have the best experience, to make sure your information is secure. 

6.3. Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance is to maintain records for tax purposes.

6.4. Consent. This legal basis is applicable only to collection and processing of adult’s Personal Data and for the cases when another legal basis listed herein is not applicable. For avoidance of doubt, all information pertaining to the Kids, including Identifiers, is processed on contractual necessity and legitimate interests’ legal basis. Since Identifiers may not be shared with third parties (except for the cases when We are obligated according to the law to share such data with Processors for the purpose of data localization) and are used only to maintain Game functioning and support of internal operations (including, but no limited to, the internal technical required operations). We presume that no adult’s consent shall be required for our processing of Kid’s data, but We still require you to read this Policy carefully, including the clauses dedicated to collection of information, pertaining to Kids.


  1. How Your Personal Data Is Processed:

7.1. We collect Your Personal Data for the implementation of the provisions according to clause 5 and other applicable clauses of this Policy;

7.2. Your Personal Data is transferred to the Personal Data Processors for the implementation of the provisions according to clause 5.3. of this Policy.


  1. A list of people who process your Personal Data as well as information about how your Personal Data is processed:


    1. Analytical services, i.e. systems that register user behavior. You can view reports in their consoles:
      • Unity and Unity Analytics
      • Yandex.Metriсa Service (AppMetrica)
      • Firebase and Google Analytics


    1. Advertising aggregators, i.e. systems that display ads in applications through the connection of various advertising networks:
      • Appodeal (if applicable)
      • Clever Ads Solutions


    1. Individual advertising networks are networks with which We do not interact directly. They are connected via ads mediation service (Clever Ads Solutions):
      • Chartboost (Android , iOS)
      • Unityads (Android , iOS)
      • Vungle (Android , iOS)
      • IronSource (Android , iOS)
      • InMobi (Android , iOS)
      • Kidoz (Android , iOS)
      • SuperAwesome (Android , iOS)
      • Admob (GoogleAds) (Android , iOS)
      • Mintegral (iOS)
      • Yandex Ads (iOS)
      • MyTarget (iOS)
  1. We can also cooperate with the third party payment services, if their usage complies with current rules of Google Play and App Store. These services can collect the above-mentioned Personal Information (clause 3.2.3. of this Policy) from adult User via authorization.

You can read the privacy policies of the respective Processor in order to find out more information about the privacy policy and the processing of personal data established in the Processor companies:

Personal Data Processor Web site on the Internet Link to the Processor’s Privacy Policy
Unity and Unity Analytics
Yandex.Metriсa Service (AppMetrica)
Clever Ads Solutions
Admob (GoogleAds)


  1. By accepting the terms of this Policy,

You agree that We may disclose the Personal Data provided by you and Kid’s data to Processors on our behalf for the purposes defined in clause 5 of this Policy, for the purposes defined in the Processor policies referred to in clause 8 of this Policy (privacy policies), provided that Identifiers may be shared only for the purpose of ensuring legal or regulatory compliance.


  1. Storage of Your Personal Data

Your Personal data and Kid’s data collected by us, as described in this Policy, is available on the territory of the Russian Federation where Our company is registered. By accepting this Policy and the terms set out therein, you agree that your Personal data is stored and processed in this country.


  1. Terms of Personal Data Storage

Your Personal Data and Kid’s data is not stored for longer than necessary to achieve the purposes for which it is collected and processed (section 5 of this Policy). The duration of the processing of the Personal User Data of our Products and/or Services is specified in the Privacy Policies of the respective Processors, but in any case, your data is stored as long as you use our Products and/or use our Services.

As soon as the purpose of collecting and processing your Personal Data is achieved and/or the statutory retention period expires, your data will be deleted or blocked.


  1. Security

We have implemented commercially reasonable technical, physical, administrative, and organizational measures designed to protect any Personal Data from accidental loss and from unauthorized access, use, modification, or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to cancel these measures or use, disclose or modify Your Personal data for improper purposes. Please also note that email and messaging systems are not considered secure, so we do not recommend sending your personal information to us using these means.

In the event that the use of User’s Personal Data has been violated as a result of a security breach, we will immediately notify the persons whose Personal Data was violated, in accordance with the notification procedure set out in this Policy, or in accordance with the requirements of the current legislation of the Russian Federation.


  1. Rights and Opportunities

13.1. In accordance with the regulations listed in paragraph 2 of this Policy, You are entitled to change or delete Your Personal Data, request access to Your Personal Data and correct it, obtain restrictions on the processing of Your Personal Data, request a copy of Your Personal Data, send an objection to the processing of Your Personal Data.
13.2. If you want to request access to Your Personal Data, make corrections to Your Personal Data, if you want to delete Your Personal Data, just send us a request by email to: We will make every reasonable effort to help You, and we will send Your request to our partners (Processors) who can access your Personal Data, and who work in accordance with their own privacy policies, the links to which we have listed in paragraph 2 hereof. We will respond to all your requests within a reasonable time.
We assure You that we will use Your Personal Data in accordance with this Policy to the extent that it is reasonably necessary for our legitimate commercial purposes, and we will use appropriate security measures to ensure the security, integrity, accuracy and confidentiality of the information that You have provided to us.
13.3. If you have any questions, comments or doubts about this Policy, please contact us by email:


  1. Rights in respect to Kid’s data

As specified herein above We do not knowingly collect any information about Kids except for non-personal data and Identifiers that Personal Data that we need to support internal operations as well as Personal Information about Kids that parents, legal representatives or adults  provide in our Applications.

If we were to collect and store information about Kids that can identify the Kid, We would obtain the consent of the parent or legal representative prior to such collection.

Please be aware that as part of the verifiable parental consent process, where applicable, parents and legal guardians will have the choice of consenting to our collection and internal use of Kid’s Personal Information but prohibiting us from disclosing that information to other entities. Additionally, any adults has the right to: (1) review, correct, or delete the Kid’s  Personal Information; and/or (2) discontinue further collection, use, or sharing of the Kid’s  Personal Information. Please note that exercising these choices may restrict your Kid’s ability to access certain functionality of the Games. 

If you believe that we may have inadvertently collected personally identifiable information about your Kid without your prior consent, you can contact us:

  • By email:


  1. Policy Changes

Our Privacy Policy may be updated on the same terms as provided for in Our User Agreement including if required by applicable law. We invite you to review our Policy from time to time in order to check changes made. Your continued use of our Products and/or Services after the update of this Policy means that you agree to such an update.

However, if you do not agree with the Policy updates, you must stop using our Products and/or Services and delete the Application and/or Game from all your devices.


  1. Contacts


Contact information:


If you contact us by email, we will use your name and email address, as well as any other information included in the email, to respond to you. We may use your Personal Data provided in your messages to contact you and send a response.