Aleksandr Govorukhin

Privacy Policy of the "Abakus" App

Alexander Govorukhin·5 Oct at 5:11 pm

Personal Data Processing Policy

1. General Provisions

This Policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (the "Personal Data Law"), Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies and Information Protection", Federal Law No. 38-FZ of 13 March 2006 "On Advertising" and other applicable legislation of the Russian Federation. This Policy sets out the approach of Aleksandr Andreevich Govorukhin (the "Operator") to processing information about users of the "Abakus" mobile app (the "App").

1.1. The Operator's primary goal and a condition of its activity is respect for human and civil rights and freedoms when handling data, including the right to privacy, personal and family secrecy.

1.2. This Policy applies to all information that the Operator and third-party services integrated into the App may obtain about users of the App.

1.3. The App does not collect or transmit to the Operator any data that the user enters. The only third-party service integrated into the App is the Yandex advertising network (Yandex Mobile Ads SDK), described in Section 6.

1.4. This Policy is a publicly available document (Article 18.1(2) of the Personal Data Law) and is published at: https://claude.ai/artifact/67cK47BMb4LofbAPP7zW5Z, and is also available within the App.

2. Definitions

2.1. Personal data — any information relating directly or indirectly to an identified or identifiable individual.

2.2. User — any person using the App.

2.3. Processing of personal data — any action or set of actions with personal data, including collection, recording, storage, transfer, anonymization and deletion.

2.4. Operator — Aleksandr Andreevich Govorukhin.

2.5. Yandex — Yandex LLC (and its affiliates), which provides ad-serving services in the App through the Yandex Mobile Ads SDK (the "Advertising Service").

2.6. Advertising identifier — a device identifier for advertising purposes (IDFA on iOS).

3. Operator Details

  • Operator: Aleksandr Andreevich Govorukhin
  • Contact e-mail: alex.govorukhin@gmail.com

4. Rights and Obligations of the Operator

4.1. The Operator undertakes to:

  • not collect or store data entered by the user in the App, and not transfer such data to third parties;
  • inform users of the current Policy and ensure unrestricted access to it;
  • obtain the user's consent to serving advertising using device data, as described in Section 7;
  • request permission for tracking (App Tracking Transparency) where required by the Apple platform;
  • not integrate any other third-party analytics, advertising or tracking services into the App without amending this Policy and notifying users;
  • handle user requests within the time limits established by Russian law.

4.2. The Operator has no access to data that the Advertising Service receives from the user's device, except for anonymized impression and revenue statistics provided by Yandex.

5. Data Entered by the User

5.1. "Abakus" is an educational app for learning to count on the abacus. All information that the user enters is stored only locally on the user's device.

5.2. This information is not transferred to the Operator, the Operator's servers, Yandex or any other third parties, and is not used to target advertising.

5.3. The App does not require registration, an account, a phone number, an e-mail address or any other identifying data, and does not request access to contacts, camera, microphone or photos.

6. Advertising in the App (Yandex)

6.1. The App contains ad units served via the Yandex Mobile Ads SDK. Advertising is selected and displayed by Yandex; the Operator is not an advertiser and does not determine the content of ads.

6.2. To serve ads, limit ad frequency, prevent fraud and calculate statistics, the Advertising Service may automatically receive the following technical data from the user's device:

  • the device advertising identifier (IDFA) — only if the user has allowed tracking;
  • IP address and approximate location derived from the IP address;
  • device and operating system information (model, iOS version, language, screen resolution, network type, mobile carrier);
  • information about interaction with ads (impressions, clicks, time);
  • other technical data listed in Yandex's documents.

6.3. This data is processed by Yandex independently under the Yandex Privacy Policy (published on yandex.ru, "Legal documents" section) and the documents governing the Advertising Service. Yandex independently determines the purposes and means of processing and is responsible for the lawfulness of processing and for storing data of Russian citizens in the territory of the Russian Federation.

6.4. The App does not transmit to Yandex the user's name, phone number, e-mail, the content of user entries, or any other data that the user enters in the App.

6.5. The user may restrict the use of data for advertising by:

  • denying tracking when the system prompt appears in the App, or in "Settings → Privacy & Security → Tracking";
  • turning off personalized advertising in iOS settings ("Apple Advertising") and in the settings available on Yandex's website;
  • withdrawing the consent described in Section 7 and ceasing to use the App.

6.6. Labeling of advertising under Article 18.1 of the Law on Advertising is carried out by Yandex as the operator of the advertising system.

7. User Consent

7.1. At first launch, the App shows the user information about advertising and invites the user to accept this Policy. By continuing to use the App after accepting the Policy, the user freely, of their own will and in their own interest, confirms consent to the transfer of the technical data listed in clause 6.2 to Yandex for the purposes stated in clause 6.2.

7.2. Consent is given for the period of use of the App and may be withdrawn at any time: by sending a message to alex.govorukhin@gmail.com, by disabling tracking and personalized advertising (clause 6.5), or by deleting the App. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

7.3. The Operator does not process special categories or biometric personal data.

8. Disclosure to Third Parties and Cross-Border Transfer

8.1. The Operator does not disclose data to third parties, except in the case described in Section 6 (transfer of technical data to Yandex through the SDK when serving ads).

8.2. The Operator does not carry out cross-border transfer of personal data. The terms of any cross-border transfer that may occur in the operation of the Advertising Service are determined by Yandex.

8.3. When the App is deleted from the device, all information entered by the user is deleted together with it, unless the device's own backup settings (for example, iCloud), which are outside the Operator's control, provide otherwise.

8.4. The Operator is not responsible for the processing of data by Apple Inc. in connection with distributing the App through the App Store.

9. User Rights

9.1. The user has the right to obtain information about the processing of their data, to require its correction, blocking or destruction, to withdraw consent, and to appeal the actions of an operator to Roskomnadzor or in court (Articles 14, 17, 20, 21 of the Personal Data Law).

9.2. For questions about data processing by Yandex, the user may contact Yandex directly using the methods stated in Yandex's policy. For all other questions, contact alex.govorukhin@gmail.com. The Operator responds within the period established by law.

10. Children

10.1. The App carries an age label of 0+ (under Federal Law No. 436-FZ; in the App Store, the minimum age rating is 4+) and contains only educational material that does not harm the health and development of children. The App and the advertising in it must comply with Federal Law No. 436-FZ of 29 December 2010 "On Protection of Children from Information Harmful to Their Health and Development".

10.2. The Operator does not knowingly collect personal data of children. For persons under 14, consent to serving advertising using device data must be given by a parent or legal representative, and the Operator recommends that they supervise children's use of the App.

11. Security

11.1. Data entered by the user is stored only on the user's device; responsibility for protecting the device (passcode, biometrics, iOS updates) lies with the user.

11.2. The Operator takes organizational and technical measures to ensure that the App does not transmit data to third parties other than as described in Section 6 (Article 19 of the Personal Data Law).

12. Final Provisions

12.1. This Policy remains in force until replaced by a new version.

12.2. If features involving the collection or transfer of data are added to the App (cloud sync, other analytics, other advertising networks), the Operator will update this Policy in advance and notify users.

12.3. The current version is available to users in the App and via the link on the App's App Store page.

12.4. Disputes are governed by the legislation of the Russian Federation.

12.5. This Policy is published in Russian and English. In case of any discrepancy, the Russian version prevails.

Last updated: 05 October 2026