Legal Information — ArdorFishing

1. Introduction

The company operating the ArdorFishing platform (hereinafter referred to as the "Company," "we," "us") is committed to protecting the privacy and confidentiality of our users' personal data. This Privacy Policy (hereinafter referred to as the "Policy") describes how we collect, use, disclose, and protect information that you provide when using the ArdorFishing platform, accessible at ardorfishing.com, through the mobile application and related services (hereinafter referred to as the "Platform").

This Policy applies to all Platform users regardless of their location. The Company complies with the requirements of Federal Law No. 152-FZ "On Personal Data" (hereinafter referred to as the "Personal Data Law"), as well as GDPR (General Data Protection Regulation) provisions for users from the European Union.

Please read this Policy carefully. By using the Platform, you agree to the terms set forth in this Policy.

2. Definitions

Personal Data — any information relating to an identified or identifiable natural person (data subject).
Processing of Personal Data — any action (operation) or set of actions performed on personal data, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Data Subject — a natural person to whom the personal data relates.
Personal Data Operator — a company or organization that determines the purposes and means of processing personal data.
Data Controller — a legal or natural person that determines the purposes and means of processing personal data (synonym for operator in Russian legislation).

3. Categories of Personal Data Collected

3.1 Data You Provide Directly

When registering and using the Platform, you provide the following information:

Registration Information:

First and last name
Email address
Phone number (optional)
Password (in encrypted form)
Profile photo (optional)
Biography and information about yourself (optional)
Date of birth (for age verification)
Country and region of residence

Fishing Information:

Geolocation data (coordinates of fishing locations)
Catch descriptions (fish species, size, weight, time)
Photos and videos of your fishing
Comments and descriptions of your fishing logs
Name of river, lake, or body of water

Marketplace Information:

Delivery address
Residential address
Payment information (last four digits of card)
Purchase and sales history

Information in Messages:

Text messages between users
Comments on other users' content
Reviews and ratings of goods/services

3.2 Data Collected Automatically

When you use the Platform, we automatically collect:

Technical Data:

Your device's IP address
Browser type and operating system
Device identifier (UDID, MAC address)
Unique application identifier (App ID)
Application and operating system version
Language and time zone
Browsing history and clicks

Activity Data:

Platform login history (date, time, IP address)
Actions you perform (views, likes, comments)
Search queries you perform
Content you create and view
Time spent on each page
Links you click

Geolocation Data:

GPS coordinates of your device (if you have granted permission)
Approximate location (by IP address)
History of places you have visited

Interaction Data:

Information about other users you interact with
Your subscriptions and friends list
Notifications you receive

3.3 Data Obtained from Third Parties

We may receive information about you from:

Payment systems and banks (when confirming payments)
Analytics services (Google Analytics, Yandex.Metrica)
Social networks (if you use social login)
Other users (mentions in comments, adding to friends list)
Partners and service providers
Law enforcement agencies (when there is a lawful request)

4. Purposes of Personal Data Processing

The Company processes your personal data for the following purposes:

4.1 Primary Purposes of Service Provision

Registration and identification — creating and managing your account
Authentication — verifying your identity and securing access
Personalization — adapting the Platform to your interests and preferences
Core functionality — maintaining fishing logs, interacting with other users, using the Marketplace
Communication — sending notifications, responding to your questions and requests
User support — technical support, problem and conflict resolution

4.2 Platform Improvement and Development

Analytics — analyzing Platform usage to improve user experience
A/B testing — testing new features and interface
Research — conducting surveys and research on user preferences
Development — using anonymized data to train recommendation algorithms

4.3 Security and Legal Compliance

Security — detecting, preventing, and investigating fraud and other unlawful activities
Rights protection — protecting the rights of the Company, users, and other parties
Legal compliance — fulfilling obligations under Russian law, including requirements of the FSB, Ministry of Internal Affairs, and other government agencies
Content moderation — reviewing and removing content that violates the Terms of Service
Legal proceedings — responding to court requests and participating in legal processes

4.4 Marketing and Advertising

Targeted advertising — displaying advertising relevant to your interests
Marketing campaigns — sending information about new features, offers, and events
Partner programs — informing about collaboration opportunities

4.5 Other Purposes

Backup — creating backups of your data for recovery in case of failure
Aggregated statistics — creating anonymized statistics for research and reports

5. Legal Bases for Data Processing

The Company processes your personal data on the following bases:

5.1 Russian Legislation

In accordance with Federal Law No. 152-FZ, the Company has the right to process personal data based on:

Subject's consent — your voluntary consent expressed during registration and use of the Platform
Contract performance — processing data necessary to provide Platform services
Legal compliance — processing data required by Russian law
Protection of interests — protecting the life, health, property, and rights of others
Obtaining and disclosing information — processing data necessary for obtaining and disclosing information in accordance with law

For EU users, the Company processes personal data based on:

Consent (Article 6(1)(a)) — your explicit consent
Contract performance (Article 6(1)(b)) — data necessary for service provision
Legal obligations (Article 6(1)(c)) — EU legal requirements
Vital interests (Article 6(1)(d)) — protection of life and health
Public interest tasks (Article 6(1)(e)) — performing tasks of public importance
Legitimate interests (Article 6(1)(f)) — balancing Company interests and user rights

6. Disclosure and Transfer of Personal Data

6.1 To Whom We Disclose Data

The Company may disclose your personal data to the following categories of recipients:

Company Employees and Contractors:

Company employees who need to know your data to perform their duties
Contractors and service providers (hosting, analytics, support)

Partners and Third Parties:

Payment systems and financial institutions (for payment processing)
Marketing and advertising partners (with anonymized data)
Social networks (if you use social login)

Law Enforcement Agencies:

Federal Security Service (FSB)
Ministry of Internal Affairs (MVD)
Prosecutor's Office
Courts
Other government agencies (when there is a lawful request)

Other Users:

Information you make public (profile, fishing logs, comments)
Messages you send to other users

6.2 Transfer of Data to Third Parties

The Company does NOT transfer your personal data to third parties for their independent use without your consent, except:

To comply with legal requirements
To protect Platform security and the rights of other users
To comply with court orders

6.3 Cross-Border Data Transfer

The Company primarily processes data on servers located in the Russian Federation. However, given the international nature of the Internet, your data may be transferred to other countries for:

Storage and backup
Payment processing
Provision of services from international partners

When transferring data to countries not recognized by the Company as providing an adequate level of protection, the Company uses appropriate safeguards (standard contractual clauses, adequacy decisions).

7. Storage of Personal Data

7.1 Retention Period

The Company stores your personal data under the following conditions:

Active Accounts:

Data is stored throughout the period of your Platform use

Deactivated Accounts:

Data is stored for 6 months after account deletion or deactivation for recovery purposes
After this period, data is deleted, except for information required by law

Logs and Backups:

Technical logs are stored for 90 days
Backups may be stored longer for disaster recovery purposes (up to 1 year)

Financial Data:

Payment information is stored for 5 years in accordance with tax law requirements

Violation Data:

Information about Terms of Service violations is stored for 3 years

Archived Data:

Anonymized and aggregated data is stored indefinitely

7.2 Storage Location

The primary storage of personal data is located in the Russian Federation. Backups may be stored in other regions (including the EU) for fault tolerance purposes.

8. Protection of Personal Data

8.1 Technical Security Measures

The Company has implemented the following technical measures to protect personal data:

Data transmission encryption — use of HTTPS/TLS protocol to protect data in transit
Storage encryption — encryption of sensitive data in databases (passwords, payment information)
Access control — use of authentication, authorization, and multi-factor authentication (MFA)
Backup — regular creation of data backups
Security monitoring — 24/7 system monitoring to detect anomalies
Asset inventory — tracking all systems storing personal data
Security updates — regular application of updates and patches

8.2 Organizational Security Measures

Designated personnel — appointment of personnel responsible for personal data protection
Employee training — training employees on data protection requirements
Confidentiality agreements — concluding confidentiality agreements with employees
Third-party contracts — requiring contractors to comply with data protection standards
Access policy — providing data access only on a need-to-know basis
Audits and inspections — conducting regular security audits
Documentation — maintaining documentation of violations and incidents

8.3 Breach Probability

Despite the security measures taken, no system can be absolutely protected from unauthorized access. The Company maintains a registry of potential incidents and is prepared to manage them in accordance with legal requirements.

If you suspect a security breach, immediately notify the Company at support@ardorfishing.com.

9. Your Rights as a Data Subject

9.1 Rights Under Russian Legislation

In accordance with Federal Law No. 152-FZ, you have the following rights:

Right of Access:

Right to receive confirmation of whether the Company processes your personal data
Right to receive a copy of your personal data

Right to Rectification:

Right to request correction of inaccurate personal data
Right to supplement incomplete data

Right to Erasure ("Right to be Forgotten"):

Right to request deletion of personal data in accordance with legal conditions
Exceptions: data necessary for legal compliance or contract performance

Right to Restriction of Processing:

Right to request suspension of data processing in case of a dispute about accuracy

Right to Portability:

Right to receive a copy of your data in a structured, commonly used format for transfer to another service provider

Right to Object:

Right to object to data processing for marketing purposes
Right to object to processing based on legitimate interests

Right to Withdraw Consent:

Right to withdraw your consent to data processing at any time
Withdrawal of consent does not affect the lawfulness of processing prior to withdrawal

Right to Protection of Rights:

Right to fair consideration of complaints
Right to apply to court to protect your rights

EU users have additional rights under GDPR:

Right to explanation of automated decision-making
Right to refuse automated decision-making (except where necessary for contract)
Right to file a complaint with a national supervisory authority (Data Protection Authority)
Right to compensation for damages in case of GDPR violation

9.3 How to Exercise Your Rights

To exercise any of the above rights, please:

Send an email to: support@ardorfishing.com
Indicate which right you wish to exercise
Provide information necessary for identification (email address, name, date of birth)
In case of suspected use of false data, the Company has the right to request additional proof

Response Times:

Russian legislation: within a reasonable time, generally no later than 30 days
GDPR: within 30 days, with possible extension of 60 days in complex cases

10. Policy Regarding Minors

10.1 Age Restrictions

Minimum age: 13 years
Ages 13 to 16: guardian consent required
Age 16 and above: can use the Platform without guardian consent (in accordance with legislation)

10.2 Child Protection

The Company takes special measures to protect the personal data of minors:

Limited data collection — collecting only necessary information
Limited use — data is not used for targeted advertising purposes
Limited disclosure — data is not transferred to third parties
Guardian verification — verifying guardian consent for users under 16
Parental control — guardians can manage their children's data

10.3 Guardian Contact

If you are the guardian of a minor using the Platform, you may:

Request deletion of the child's account
Access the child's data
Change privacy settings

To do so, write to support@ardorfishing.com with the child's information and proof of your guardian status.

11. Cookies and Similar Technologies

11.1 What Are Cookies

Cookies are small data files that the Platform saves on your device to remember information about you and your preferences.

11.2 Types of Cookies We Use

Strictly Necessary Cookies:

Session cookies (for Platform operation)
Authentication cookies (for login)
Security cookies (for attack protection)

Functionality Cookies:

Remembering user preferences
Saving language settings

Analytical Cookies:

Google Analytics (usage analysis)
Yandex.Metrica (visit statistics)

Marketing Cookies:

Retargeting (displaying ads on other sites)
Conversion tracking

11.3 Managing Cookies

You can manage cookies in your browser settings:

Chrome: Settings → Privacy and security → Cookies
Firefox: Settings → Privacy → Cookies
Safari: Preferences → Privacy → Cookies
Edge: Settings → Privacy → Cookies

When deleting cookies, some Platform features may not work correctly.

11.4 Tracking (Do Not Track)

Some browsers support the "Do Not Track" feature. If you activate this feature, the Company will attempt to respect your choice but cannot guarantee complete absence of tracking.

12. Third-Party Services and Integrations

12.1 Third-Party Payment Systems

When making payments, your information is transferred to payment systems:

Yandex.Checkout
PayPal
Stripe
MasterCard, VISA

These systems have their own Privacy Policies that apply to the processing of your payment data.

12.2 Analytics Services

We use the following analytics services:

Google Analytics — Platform usage analysis
Yandex.Metrica — visit statistics

These services collect data about your behavior. You can opt out by installing a browser plugin.

If you use social login (Google, VK, Telegram), the Platform receives certain information from your social network profile. The social network's Privacy Policy applies.

12.4 Sub-processors

The Company uses the following sub-processors for data processing:

Hosting: Digital Ocean, AWS
Email: SendGrid
SMS: Twilio
Analytics: Google LLC, Yandex LLC

A complete list is available upon request at support@ardorfishing.com.

13. Updates to the Privacy Policy

The Company may update this Policy at any time. When making significant changes, we will notify you:

By email to the address specified in your profile
By notification in the application
By posting a notice on the Platform

Significant changes take effect 30 days after notification. Your continued use of the Platform after this period constitutes acceptance of the new terms.

The date of the last update is indicated at the beginning of this document.

14. Contact Information for Privacy Questions

If you have questions, concerns, or complaints regarding this Policy or the processing of your personal data, please contact us:

Primary Contact:

Email: support@ardorfishing.com
Website: ardorfishing.com
Support chat: https://ardorfishing.com/support

Company Address:

Company legal address

Data Protection Officer:

Name, position, contact details

Response Time: The Company undertakes to respond to your request within 5 business days.

15. Supervisory Authorities

If your rights are violated, you may contact the following authorities:

Russian Federation:

Federal Service for Supervision of Communications, Information Technology, and Mass Media (Roskomnadzor)
Address: https://rkn.gov.ru/
Phone: +7 (495) 550-00-74

European Union:

European Data Protection Board (EDPB)
https://edpb.ec.europa.eu/
National Data Protection Authorities (DPA)

16. Special Provisions for Residents of Certain Countries

16.1 California (CCPA)

California residents have additional rights under the California Consumer Privacy Act (CCPA):

Right to know what personal data is collected
Right to delete personal data
Right to opt out of the sale of personal data
Right to non-discrimination for exercising their rights

16.2 Virginia (VCDPA)

Virginia residents have similar rights under the Virginia Consumer Data Protection Act (VCDPA).

16.3 Other Jurisdictions

For residents of other countries with similar legislation, analogous data protection principles apply.

17. Data Processing in Security Breaches

17.1 Incident Notification

Upon confirmation of a security breach that may affect your personal data, the Company will:

Notify you by email without undue delay
Provide information about the type of breach
Explain the likely consequences
Describe measures taken to protect your data
Provide contact details for additional information

17.2 Legal Notification

When necessary, the Company will also notify:

Roskomnadzor (in accordance with Russian legislation)
National Data Protection Authorities (in accordance with GDPR)
Law enforcement agencies

18. Data Archiving and Deletion

18.1 Long-Term Storage

The Company may retain archived and anonymized versions of your data after account deletion for purposes of:

Historical research
Statistical analysis
Legal proceedings

This data cannot be used to identify you.

18.2 Complete Purge

You may request complete purging of all your data, including archives, subject to the following conditions:

Data necessary for legal compliance is retained
Processed data is deleted according to the deletion schedule

19. Emergency Situations

In the event of a state emergency, war, terrorist threat, or other extreme circumstances, the Company may:

Transfer personal data to law enforcement and military structures without your consent
Use data to ensure national security
Restrict access to the Platform

By visiting and using the ArdorFishing Platform, you:

Confirm that you have read and understand this Privacy Policy
Give your explicit consent to the processing of your personal data in accordance with this Policy
Acknowledge that you have provided accurate information during registration
Agree to the terms of data storage and protection
Understand the risks of using the Internet and the Platform

If you do not agree with any part of this Policy, please discontinue use of the Platform.

Thank you for trusting ArdorFishing — the platform for passionate anglers!

This Privacy Policy is aligned with:

Federal Law No. 152-FZ "On Personal Data" of the Russian Federation
General Data Protection Regulation (GDPR) of the European Union
California Consumer Privacy Act (CCPA)
International data protection standards