Privacy policy

Revision dated June 04, 2025

1. What this privacy policy governs
This Privacy Policy (hereinafter - Policy) applies to all information, including personal data in the understanding of applicable law (hereinafter - "Personal Information"), which "Cyber Plus" LLC (hereinafter - Operator) may obtain about you through your use of the Operator’s website, programs, products and/or services (hereinafter jointly "Services"), information about which you can find on the website https://tmgame.ru (hereinafter jointly "Site"), as well as in the course of the Operator’s performance of any agreements and contracts concluded with you in connection with your use of the Services. The Operator may also receive Personal Information from its partners (hereinafter "Partners"), websites, programs, products, or services that you use, from other sources with publicly available personal data. In appropriate cases, the transfer of Personal Information is possible only in the cases established by applicable legislation and carried out on the basis of special agreements between the Operator and each of the Partners. 

2. Who processes the informationa
To ensure your use of the Site and Services, your Personal information is collected and used by the Operator. 

3. What is the purpose of this Policy
When you use the Sites and Services, the Operator protects and processes your Personal Information in strict compliance with applicable law.
The Policy contains information on:
(a) why and how the Operator collects and uses ("processes") your Personal Information when you use the Site and/or the Services;
(b) what is the Operator’s role and responsibilities as the legal entity that decides why and how to process your Personal Information;
(c) what tools you can use to reduce the amount of Personal Information collected by the Operator about you;
(d) What are your rights in relation to the processing of Personal Information.

4. What Personal Information about you is collected by the Operator
The Personal Information collected while operating the Site and/or providing the Services may differ depending on whether you use your account to access them or not. When you log in to your account, the Personal Information collected about you by the Operator during your use of the Site and Services may be matched and linked with other Personal Information collected by the Operator in connection with your use of your account (for example, your identity data, contact details, age and gender if provided to the Operator). The Operator does not verify the Personal Information provided by you, except as provided for in the user agreement or terms of use of individual Services, and cannot judge its reliability, nor can it determine whether you have sufficient legal capacity to provide your Personal Information. Nevertheless, the Operator assumes that you provide reliable and sufficient personal information and update it in a timely manner.
The Operator may collect the following categories of Personal Information about you when you use the Site and Services:
(i) Personal information provided by you when registering (creating an account), such as username, password, e-mail address, IP address, location, social network or external platform account details (when registering/creating an account via: VK, ODK, Google, Mail.ru, Yandex).
After creating an account, you have the possibility to confirm your e-mail address for receiving mails (you can cancel your subscription at any time by either clicking on the "unsubscribe" link at the end of each mail or on the account page in the "Other features" section, "Subscription");
(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser identifier data, hardware and software information);
(iii) the date and time of accessing the Site and/or the Services;
(iv) information about your activity while using the Site and/or the Services (for example, game data (level of play, rewards, ratings, playing time, use of various features, as well as data related to possible errors and faults); IP address, date and time of login, browser and operating system used; data when communicating with other players (forum, project chat, social media pages of the project, username in the forum/chat of the project, IP address (forum), date of registration on the forum date of last visit to the forum, date and time of the user’s message (forum, project chat); information about participation in a contest or survey organized by the Operator (username, e-mail address, other data depending on the topic of the survey); Data about purchases in the Services, e-mail addresses, information about interaction with other users as well as files and content, stored in the Operator's systems);
(v) geolocation information;
(vi) other information about you that is necessary for processing under the terms governing the use of the Site or Services of the Operator;
(vii) information about you that we receive from our Partners under the terms of agreements concluded between you and the relevant Partner, and agreements concluded between the Operator and the Partner;
(viii) your payment card details (first and last bank card numbers), username, e-mail address, purchase price, product purchased, currency of purchase, date and time of purchase, transaction ID, quantity of goods purchased (crystals), other payment information provided by you, as well as received from Partners or other persons involved in carrying out a payment transaction using the Site or the Services of the Operator and/or in connection with the provision of paid services by the Operator (https://shop.tmgame.ru/).
The Operator also uses cookies to collect Personal Information and link such Personal Information with your device and web browser.
The Operator does not collect Personal Information such as racial background, political views, health information, and biometric data. 

5. What is the legal basis and purpose of processing your Personal Information
The Operator does not have a right to process your Personal Information without sufficient legal basis. Therefore, the Operator processes your Personal Information only if:
(i) processing is necessary for the performance of contracts between you and the Operator, such as the Operator’s Service User Agreement https://tmgame.ru/ua.php) and the terms of provision of individual Operator’s Services, which includes providing the operation of the Sites and Services (for example, providing you with search results based on your search requests);
(ii) processing is necessary to comply with the legal obligations;
(iii) when required by applicable law, processing is necessary to ensure the legitimate interests of the Operator if such processing does not have a significant impact on your interests, your fundamental rights and freedoms. When processing your personal information on the stated basis, the Operator will always strive to maintain a balance between its legitimate interests and the protection of your privacy.
The Operator processes your Personal Information to ensure its legitimate interests, for example, in the following cases:
(a) to better understand how you interact with our Site and/or Services;
(b) to perfect, change, personalize or otherwise improve the Site and the Services for the benefit of all users;
(c) to offer you other products and services of the Operator or other companies that we believe may be of interest to you (i.e. to show you advertising tailored to your interests);
(iv) for specific purposes or as required by applicable law, we may request your separate consent to the processing of your Personal Information. We hereby inform you and you acknowledge that you have no obligation to provide us with any Personal Information when using the Sites or the Services, and such provision is based solely on your free will. Nevertheless, you understand that without providing Personal Information we will not be able to provide you with the ability to use the Services and your use of the Site will be limited.
The Operator always processes your Personal Information for specific purposes and only that Personal Information which is relevant to achieving such purposes. In particular, we process your Personal Information for the following purposes:
(i) providing you with access to the Site and/or Services (i.e. providing search results in response to your search queries based on your preferences, search history and other Personal Information about you available to the Operator);
(ii) providing access to your account if you are registered on the relevant Services;
(iii) to communicate with you in order to send you notifications, requests and information related to the operation of the Site and the Services, to execute agreements with you and to process your requests and applications;
(iv) improving the usability of the Site and the Services, as well as improving other products, applications and Services of the Operator;
(v) creation of new products, utilities and offers of the Operator;
(vi) protection of your rights and the Operator’s rights;
(vii) identification of security threats to the Site and the Services, users, the Operator;
(viii) arranging payment acceptance, your payment for goods and services using the Site and the Services.

6. How the Operator protects your personal information
In most cases, Personal Information is processed automatically without access by any of the Operator’s employees. If such access is required, it may be granted only to those Operator employees who need it to perform their tasks. In order to protect and ensure the confidentiality of data, all employees are required to comply with internal rules and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect your Personal Information.
The Operator uses sufficient technical and organizational measures to protect Personal Information from unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access, as well as other unlawful forms of processing. These security measures have been implemented considering the state-of-the-art technology, risks associated with processing and the nature of Personal Information.

7. Who else has access to your Personal Information and to whom it may be transferred
7.1. The Operator may disclose your Personal Information to its employees (within the limits set out in section 6 of this Policy). The Operator may also share your Personal Information with its affiliates.
Unless otherwise specified by the terms of use of the Site and/or Services provided by the Operator, in all cases Personal Information will be processed only for the purposes set out in section 5 of this Policy. Your Personal Information may be transferred to the following:
• "Paymaster" LLC. (TIN 7723887394, legal address: 107241, Moscow, Gol'yanovo Municipal District, Shchyolkovskoye Hwy, 23A, room 7/7) - for the purpose of making payments when using the Site and/ or Services of the Operator and/ or its partners through the site: info.paymaster.ru;  https://paymaster.ru/.
• "Yoomoney" NCO LLC. (TIN 7750005725, address: 115035, Moscow, Sadovnicheskaya St., 82 Bldg. 2) - for the purpose of making purchases and payments through websites: https://yoomoney.ru/.
• "Xsolla" LLC. (TIN 5902879646, address: 614000, Perm region, Perm, Komsomolskiy Ave. 1, entrance 2, floor/office 6/3) - for the purpose of investing, promoting, launching and monetizing the Site and/ or Services (https://xsolla.com/ru).
• "ALFA-BANK" JSC. (TIN 7728168971, address: 107078, Moscow, Kalenchevskaya Street, 27) - for the purpose of making payments when using the Site and/ or Services Operator and/ or its partners (https://alfabank.ru/, through paykeeper.ru).
•  "VK" LLC. (TIN 7842349892, address: 191024, Saint-Petersburg, Khersonskaya St., 12-14 A, room 1-n) - for the purpose of interaction with other users and making transactions when using the Site and/ or Services (https://vk.com/).
• "Yandex" LLC. (TIN 7736207543, address: 119021, Moscow, Leo Tolstoy St., 16) - for the purpose of additional functions/ possibilities of the Site and/ or Services, as well as to attract new users (https://direct.yandex.ru).
7.2. The Operator may also transfer Personal Information to third parties for purposes specified in section 5 of this Policy.
Such third parties may include:
(i) Partners, such as website and application owners, advertising networks and other partners providing services to the Operator related to the placement and display of advertisements on the site, in programs, products or services owned or controlled by such partners;
(ii) persons involved in organizing the receipt of your payments and carrying out payment transactions using the Site and the Services (payment systems, payment instrument providers, banks and other financial institutions, etc.).

The Operator may also transfer Personal Information to the following third parties:
(i) any state regulatory authority, law enforcement agency, central or local executive authority, other official or state authority or court, for which the Operator is obliged to provide information in accordance with applicable law upon request;
(iii) third parties, if you have consented to the transfer of your Personal Information or the transfer of Personal Information is required to provide you with the relevant Service or to perform a certain agreement or contract concluded with you;
(iv) any third party for the purpose of providing legal protection to the Operator or third parties in the event of violating the Operator’s Services User Agreement (https://tmgame.ru/ua.php) by you, this Policy or the terms governing the use of individual Services, or in a situation of a threat of such violation.

8. Where your Personal Information is stored and processed
Your Personal Information will be stored in the territory of the Russian Federation.
For Russian users: The operator performs recording, systematization, accumulation, storage, clarification (update, change), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.
For users from other countries: Russia is a jurisdiction outside the European Economic Area, which was not recognized by the European Commission as ensuring an adequate level of personal data protection. The Operator has therefore taken appropriate measures to ensure that such transfer is carried out in accordance with current EU data protection rules.
The Operator is guided by the standard contractual terms approved by the European Commission to ensure an adequate level of protection of your Personal Information transferred to Russia. A copy of these standard contractual terms is available upon request.
If you are located in a territory where your consent is required for the transfer of your Personal Information to another jurisdiction by using the Site or the Services, you give the Operator your explicit and unequivocal consent to such transfer or storage and/or processing information in other specified jurisdictions, including Russia.

9. How long we keep your Personal Information
The Operator will keep your Personal Information for as long as necessary to achieve the purpose for which it was collected, or to comply with legal and regulatory requirements.
Unless otherwise required by law or agreement with you, the Personal Information stored on the Site and/or Services will be kept for as long as you have an account, but it may be deleted by you at any time.
If you wish to have any of your Personal Information removed from the Operator’s databases, you may independently delete the necessary Personal Information through the Site and/or Services interface (where applicable). 

10. Your rights
10.1. What rights do you have:
You have the right to access your Personal Information processed by the Operator in accordance with this Policy.
If you believe that any information that the Operator holds about you is incorrect or incomplete, you may log into your account and correct your Personal Information yourself.
You have the right:
• to view information that the Operator holds about you, including through your account;
• require the removal of your Personal Information or any part thereof, and withdraw consent to the processing of your Personal Information;
• require restrictions on the processing of your Personal Information.
The Operator will execute the specified requests in accordance with applicable law.
In cases provided by applicable law, you may also have other rights not mentioned above.
When you use the Services, the transfer of Personal Information is done with your consent expressing your free will and interest (in particular on the basis of a contract with you) and is not an obligation under law.
10.2 How you can exercise your rights:
To exercise the above rights, you must log in to your account, and if there is no special function in the interface, contact the Operator.

11. How we use cookies and other similar technologies on the Site or when you use the Services
11.1. Which cookies and why the Operator uses them:
Cookies are small pieces of data that are accepted and processed by the device you use to access the Site. Cookies store and send back to the Site information that helps your work with the Site and allows us to remember your preferences over time, such as browser settings or recognizing your account.
The Site uses the following types of cookies:
• strictly necessary cookies/ technical cookies: these cookies are necessary for the operation of the Site and the provision of Services to you; among other things, they allow the Operator to identify your hardware and software, including your browser type;
• Statistical/analytical cookies: these cookies allow us to recognize users, count their number and collect information such as the operations you perform on the Site and the Services, including information about the web pages you visit and the content you receive;
• Technical cookies: these cookies collect information about how users interact with the Site and/or the Services, which allows you to detect errors and test new features to improve the performance of the Site and the Services;
• Functional cookies: these cookies provide certain functions to facilitate your use of the Site, for example by keeping track of your preferences (such as language and location).
11.2. How long cookies are stored on your device:
The Operator uses the information contained in the cookie files only for the purposes specified above, after which the collected data will be stored on your device for a period that may depend on the type of cookie but not exceeding the time necessary to achieve their purpose, after which they will be automatically removed from your system.
11.3. Who else has access to the information contained in cookie files:
Personal Information collected through cookies placed on your device may be transferred and made available to the Operator and/or third parties specified in section 7 of this Policy. Use of Personal Information outside the Site for advertising purposes, if any, may be subject to separate user agreements available on third-party websites.
When you first visit the Site, your consent to the use of cookies may be requested. If after you have approved the use of cookies, you would like to change your decision, you can do so by deleting the cookies stored in your browser (you can usually do this in your browser’s settings - please refer to the browser manual or its developer’s website). After this, a pop-up window requesting your consent may be displayed again and you can make a different choice. If you opt out of the use of cookies, this may result in some features of the Site not being available to you and will affect your ability to use the Site. You can also change your browser settings to accept or reject by default all cookies or cookies from certain sites, including the Operator’s Site.

12. Updating current Policy
This Policy is subject to change. The Operator has the right to make changes at its own discretion, including but not limited to where such changes are related to changes in applicable law and where such changes are related to changes in the operation of the Site and the Services.
The Operator undertakes not to make any material changes, impose additional burdens or limitations on your rights set forth in this Policy without your notice. You will be notified of such changes. Relevant notices may be displayed on the Site or in the Services (for example, through a pop-up window or banner) before such changes take effect, or may be sent to you via other communication channels (for example, by e-mail if you provide us with your contact details).

13. Questions and suggestions
The Operator welcomes your questions and suggestions regarding the execution or modification of this Policy. Please use our feedback form at  https://tmgame.ru/bug_report.php?problem. You can also use this address to send requests for the exercise of your rights or complaints about the incorrectness of your Personal Information or the illegality of its processing.