Date of last revision: 01.11.2025

Privacy Policy
BLACKHUB GAMES - FZCO

This Privacy Policy (hereinafter referred to as the "Privacy Policy" or "Policy") sets out the terms and conditions for the processing of personal data by BLACKHUB GAMES - FZCO (Address: DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, registration number: DSO-FZCO-40614).

Use of the Resources specified in this Policy, as well as the Black Russia online game (collectively referred to as the "Resources") implies the User's consent to this Policy and the terms and conditions for the processing of personal data. If the User does not agree with the terms of the Policy, they must stop using the Resources and the services available through them (hereinafter referred to as the "Services").

1. General Provisions

1.1. This Policy regulates any type of processing of personal data and personal information about Users of the Resources, including any actions (operations) or set of actions (operations) performed with or without the use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

1.2. Within the framework of this Policy, the User's personal information is understood to mean:

1.2.1. Personal information that the User provides about themselves independently in the process of using the Services of the Resources.

1.2.2. Data that is automatically transmitted to the Resource Services during their use by means of software installed on the User's device, including IP address, cookie data, information about the User's browser (or other program used to access the services), technical characteristics of the equipment and software used by the User, the date and time of access to the services, the addresses of the requested pages, and other similar information.

1.3. The purpose of this Policy is to ensure the protection of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets, and the protection of information from unauthorized access and disclosure.

1.4. All personal data collected during visits to the Resources is used by the Company only for the purposes specified in this Policy, as well as to improve the quality of the Resources as a whole or to process User requests.

1.5. The collection and processing of personal data of visitors to the Resources is carried out in strict accordance with UAE legislation on the protection of personal data (UAE Federal Law No. 45 of 2021 on the protection of personal data).

1.6. The Company is not responsible for third-party websites that the User may access via links available on the Company's Resources.

2. Key Terms

2.1. Cookies - a small piece of data sent by a web server and stored on the User's device.

2.2. Account - a User account created on the Company's Resources, which is used to access the Game and Services.

2.3. Game - software called "BLACK RUSSIA," designed to be installed and used on Devices.

2.4. Resources - locations where the Policy is posted:

The Resources also include other products and applications (including support applications and forums) related to the Black Russia Game, which contain a link to this Policy.

2.5. Personal data processing is any action (operation) or set of actions, performed with or without the use of automation tools, involving personal data, including collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.6. Personal data operator - a legal entity or individual that processes personal data. When the User receives services, the Company becomes the operator of the Users' personal data.

2.7. Personal data is any information relating directly or indirectly to a specific or identifiable User of the Resources and/or the Game.

2.8. User - any visitor to the Company's Resources.

2.9. Services - interactive (dialog) software components on the pages of the Resources specified in clause 2.4. of the Policy, which are used for integration with information systems and provide users of the Resources with certain opportunities to access information on them.

2.10. Device - any technical device that allows the use of the Resources and the Game in accordance with its functional purpose.

3. Purposes of Personal Data Processing

3.1. The Company processes personal data in order to fulfill its obligations to Users in connection with the use of the Company's Resources and the Services posted on them. Viewing the Resources does not require the mandatory provision of personal information and personal data; however, without providing contact information, visitors to the Resources will not be able to receive information addressed to them and receive certain services provided by the Company.

3.2. The Company may use personal information for the following purposes:

3.2.1. To identify a person as a User of the Resources;

3.2.2. To create a convenient environment on the Resources;

3.2.3. To improve the quality of services provided by the Company;

3.2.4. To communicate with the User in the process of providing services and sending them notifications and information about services, as well as to provide answers to Users' questions;

3.2.5. To conduct statistical and analytical research in the field of advertising and traffic on the Resources based on anonymized personal information.

3.2.6. When creating an account on the Resources and/or on any server associated with them and managing it;

3.2.7. When participating in testing additional game services and/or updates to the Service (if applicable);

3.2.8. When participating in in-game promotions, competitions, and other similar events;

3.2.9. When sending requests, letters, or other types of communications to the Service administration;

3.2.10. When using additional, special services within the Game.

4. Collection of Personal Data

4.1. The processing of Users' personal data is carried out only with their consent. Users provide personal data about themselves independently, of their own free will and in their own interest when filling out forms on the Company's Resources.

4.2. Personal data may also include additional data that Users provide at the request of the Company when necessary for the Company to fulfill its obligations to Users, or at their own discretion. The goal is to ensure that the stored data about Users is accurate and up-to-date.

4.3. The Company will endeavor to update information in a timely manner and not store data longer than necessary.

4.4. The Company does not verify the accuracy of the personal information provided by Users, but assumes that the User provides accurate and sufficient personal information and keeps this information up to date.

4.5. Users may change (update, supplement) the personal information provided or part thereof at any time by sending a written request to the following email address: support_br@blackhub.games.

4.6. Users always have the right to request the removal of their personal data from the Company's databases. The Company shall delete the relevant personal data no later than 10 (ten) days from the date of receipt of the User's request at in accordance with the procedure set forth in this Policy.

4.7. The Company does not process biometric data, as well as information relating to race, nationality, political views, religious or philosophical beliefs, the intimate life of personal data subjects, or information about criminal convictions.

4.8. The Company may collect certain data (e.g., IP address, username, game actions) to detect, investigate, and prevent fraudulent activities, violations of the Game rules, and terms of the user agreement. Such data is used exclusively for the specified purposes and is deleted within the time limits established by internal regulations, unless otherwise required to prove the fact of a violation within the statute of limitations.

5. Principles of Personal Data Processing

5.1. The company processes personal data based on the following principles:

6. Storage and Use of Personal Data

6.1. All personal data that Users provide to the Company when visiting the Resources will be stored on a specially protected server and processed using automated systems, except in cases where non-automated processing of personal data is necessary to comply with legal requirements or to provide services.

6.2. The Company takes all technical, organizational, and legal measures, including, if necessary, encryption, to protect Users' personal data from any unauthorized access or alteration.

6.3. Users' personal data is stored in the Russian Federation.

6.4. Personal data and information about Users will be stored for the period necessary to fulfill the purposes for which they were provided, except in cases where a longer period of data and information storage is required by law.

6.5. Company employees have access to Users' personal data only to the extent necessary for them to perform their job duties related to the provision of services. At the same time, all rules for working with personal data are strictly observed by the Company.

6.6. The Company maintains the confidentiality of Users' personal data, except in cases where Users themselves provide information about themselves for access by third parties.

6.7. The Company cares about data security in order to prevent unauthorized access to it by other persons.

7. Transfer and Processing of Personal Data

7.1. The Company processes Users' personal data and may transfer it to third parties for the purposes of fulfilling the terms of the agreement, complying with legal obligations, and realizing the Company's legitimate interests, except in cases expressly provided for by the legislation of the Russian Federation.

7.2. The transfer of the User's personal data to third parties is carried out in the following cases:

7.3. The Company also has the right to disclose anonymous and aggregated data (which does not allow the User to be identified) to advertising partners and other third parties for analysis, marketing, and improvement of the Company's Resources.

7.4. The Company blocks the User's personal data from the moment it receives a corresponding request from the User or an authorized body for the protection of the rights of personal data subjects, if it is found that the personal data is inaccurate or that such data is being used for unlawful activities.

7.5. The processing of Users' personal data is carried out without any time limit by any legal means, including collection, recording, systematization, storage, clarification, use, transfer, depersonalization, blocking, deletion, and destruction.

7.6. In the event of loss or disclosure of personal data, the Company shall inform the User of the loss or disclosure of personal data.

7.7. The Company takes the necessary organizational and technical measures to protect Users' personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions by third parties.

7.8. The Company, together with the User, shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of their personal data.

8. Rights and Obligations of the Parties

8.1. Users are obliged to:

8.1.1. Provide personal data necessary for using Resources.

8.1.2. Update and supplement the personal data provided in the event of changes to this information.

8.2. Users have the right to:

8.2.1. access their personal data;

8.2.2. to clarify personal data;

8.2.3. to block and delete personal data;

8.2.4. to appeal against the actions or inaction of the Company;

8.2.5. to appeal decisions made based solely on automated processing of your personal data;

8.2.6. to withdraw consent to the processing of personal data;

8.2.7. to exercise other rights of a personal data subject in accordance with the Personal Data Law.

8.3. The Company is obliged to:

8.3.1. Use the information received solely for the purposes specified in this Policy.

8.3.2. Ensure that confidential information is kept secret, not disclosed without the prior written consent of Users, and not sold, exchanged, published, or disclosed in any other way, except as provided for in this Policy.

8.3.3. Block personal data relating to the relevant User from the moment of their request or that of their legal representative or authorized body for the protection of the rights of personal data subjects for the period of verification in the event of the discovery of inaccurate personal data or unlawful actions.

9. Personal Data Protection

9.1. The Company takes necessary and sufficient measures to protect the personal data of Users, including legal, organizational, administrative, technical, and physical measures - in accordance with UAE Federal Law No. 45 of 2021 on the protection of personal data in order to ensure the protection of the User's personal data from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions by third parties. Data security is implemented by means of network protection software.

9.2. The Company guarantees the security of Users' personal data only when using the Resources.

9.3. The Company notes that it does not control and is not responsible for third-party websites that the User may visit via links while using the Resources or the Company's services, including social networks. Third-party websites may collect and request other personal information from the User, as well as use it for their own purposes. The actions of third-party websites should be governed by the rules for working with personal data of such websites.

9.4. The Company's personal data security measures include, among others, the following:

10. Collection and Use of Information, Not Personal

10.1. When viewing the Resources, reading texts on its pages, and downloading other information, certain data about the computer from which Users view the Resources is automatically recorded. This information is not personal and is collected for the purpose of anonymously counting the number of visitors to the Resources and its individual pages, as well as determining the types of computers and software used.

10.2. Cookies are used as a tool for collecting the information specified in clause 7.1 of this Policy.

10.3. When viewing the Resources, the Company collects the following data:

11. Use of Cookies

11.1. The Company uses technologies such as cookies and pixel tags to facilitate the use of the Resources and to provide Users with the most relevant content. A cookie is a small file used to store web browsing settings. During the first visit to the Resources, this file is downloaded using a browser. The next time you visit the Resources from the same device, your browser may check for the presence of a related cookie (i.e., one containing the name of the Resource) and use the data in that cookie to send it back to the corresponding Resource. This allows the Resources to determine that they have already been visited from that browser and, in some cases, to change the content displayed.

11.2. The Company uses both its own cookies and third-party analytics tools to collect data on the Resources.

11.3. Categories of cookies that may be used on the Resources:

11.3.1. Mandatory (strictly necessary) cookies. These are necessary for the Resources to function and provide their basic features, such as page navigation, security, and access to secure areas.

11.3.2. Functional cookies. Used to remember user settings and preferences, such as the selected interface language or region.

11.3.3. Analytical cookies. These are used to collect statistics and analyze user behavior on the Resources in order to improve the quality of the Services. In particular, the Resources use the Yandex Metrica web analytics service, which uses cookies to collect anonymous information about user visits and actions.

11.3.4. Marketing (advertising) cookies. These cookies are used to display relevant advertising and evaluate the effectiveness of advertising campaigns. They can be collected by both the Company and its partners.

11.3.5. If Users wish to change how their browser uses cookies, including blocking or deleting cookies from the Resources, they can do so at any time using their browser settings. Instructions for managing cookies for popular browsers are available at the following links:

If you disable, delete, or refuse to accept cookies, some features or functions of the Resources may become unavailable or may not work properly.

12. User Requests

12.1. Users have the right to send requests to the Company related to the use of personal data, as well as statements of withdrawal of consent to the processing of personal data in writing to the email address specified in section 11 of this Policy.

12.2. The request must contain the User's passport details or other identity document, and information confirming that the Company processes the relevant personal data (for example, a link to the form filled out on the Resources), and the signature of the User or legal representative.

12.3. The Company undertakes to review and respond within 10 (ten) days of receiving the request.

13. Final Provisions

13.1. In all other respects not covered by this Policy, the Company undertakes to comply with the rules and regulations of UAE Federal Law No. 45 of 2021 on the protection of personal data.

13.2. Users agree to the provisions of this Policy if, when visiting the Company's Resources, they have provided their personal data and information by filling out a form on the Resources.

13.3. The Company reserves the right to make any changes to the Policy at any time at its discretion in order to further improve the system of protection against unauthorized access to personal data provided by Users. In the event of changes to the Policy, the policy is published in the public domain on the Company's Resources. This Policy does not apply to actions taken on third-party websites.

14. Feedback

14.1. All suggestions and questions related to this Policy and/or the functioning of the Resources should be sent to the following email address: support_br@blackhub.games.