Sole proprietor Elena Leonidovna Saltykova (Individual Entrepreneur, Russian registration number OGRNIP 323350000008567), address: 28 Kosmonavta Belyaeva St., Cherepovets, 162616, Russia (the "Platform," "we," "us") is the data controller for the CyberPass mobile application (the "App") for iOS and Android.

This Privacy Policy (the "Policy") describes what data we collect through the App, how we use it, who we share it with, and what rights you have. By using the App, you agree to this Policy.



1. Data we collect


We do not collect or store payment card data. The App currently does not process subscription payments directly; if in-app payment is introduced in the future, this Policy will be updated accordingly.

Analytics. As of the effective date, the App does not use third-party usage-analytics services beyond standard Firebase statistics related to push notifications. We may in the future integrate analytics tools (such as Firebase Analytics, Yandex Metrica, AppMetrica, or similar) and crash-diagnostic tools (such as Crashlytics or Sentry). If we do, this Policy will be updated, and the current list of tools will be reflected in the App Store's App Privacy disclosure and Google Play's Data safety section.

2. Purposes of processing

• creating and maintaining your user account;
• authenticating you in the App via phone number;
• providing access to the Service, including crediting and debiting minutes/hours on your digital subscription;
• booking gaming sessions with the Service Provider;
• sending push notifications about your balance and other service information;
• handling support requests;
• complying with applicable Russian law.

3. Who we share data with
We share certain data with third-party services required to operate the App. These providers act as data processors and are contractually limited to using the data only to provide their service to us:

• Zvonok.com — call-based authentication provider; receives only the user's phone number. zvonok.com
• BookNow.ru — booking provider; receives name, phone number, and the date/time/status of the booking. Their privacy policy: booknow.ru/business/page/privacy-policy.html
• Firebase (Google) — push notifications on Android; Apple Push Notification service — push notifications on iOS.

Data is shared with Service Providers only through the Platform, and only to the extent needed to deliver the Service (for example, displaying your QR code at the point of service). We do not sell personal data to third parties and do not share it for purposes unrelated to providing the Service.

4. Where data is stored
User data is stored on servers located in the Russian Federation.

5. Retention period
We retain personal data for as long as your account is active. After account deletion, data is retained for no more than one (1) year, except where longer retention is required by Russian law (for example, for tax or accounting purposes).

6. Your rights
You may:

• delete your account yourself in the App's settings;
• request access to, correction of, or deletion of your personal data;
• withdraw your consent to data processing and to receiving marketing communications;
• file a complaint with Roskomnadzor (for users in Russia) or with your local data protection authority (for users outside Russia).

To exercise these rights, or with any questions about how we process your data, contact us using the details in the "Contact" section.

7. Users outside Russia
The App is available for download worldwide. If you are located outside Russia, including in the European Union, your data may also be processed in accordance with the General Data Protection Regulation (GDPR) in addition to Russian law. The legal basis for processing is performance of a contract (provision of the Service) and consent. We apply reasonable organizational and technical measures to protect data regardless of your location.

8. Age restriction
The App is intended for users aged 18 and older. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, please contact us and we will delete it.

9. Data security
We use reasonable technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure.

10. Changes to this Policy
We may update this Policy from time to time, in particular when we integrate new analytics services, payment solutions, or other data-processing tools. The "last updated" date at the top of this document reflects the most recent revision. We will notify users of material changes via push notification, email, or another reasonably available method.

11. Contact
Elena Leonidovna Saltykova, Sole Proprietor (IE)
Registration No. (OGRNIP): 323350000008567
Address: 28 Kosmonavta Belyaeva St., Cherepovets, 162616, Russia
Email: support@cyberpass.tech