Privacy Policy

This Privacy Policy (hereinafter — the "Policy") describes the processing and protection of information that the Administration of the "AnonApp" mobile application (hereinafter — the "App") receives about Users (hereinafter — the "User", "You") when using the App.

By using the App, You freely, of Your own will and in Your own interest, give consent to the processing of Your data in accordance with the terms of this Policy. If You do not agree with any provisions, immediately cease using the App.

1. General Provisions

1.1. This Policy is developed in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data", and also takes into account the requirements of other applicable regulations, including, where applicable, Regulation (EU) 2016/679 (GDPR) and the legislation of the countries in which the User accesses the Service.

1.2. The purpose of the Policy is to ensure the protection of the rights and freedoms of Users when processing their information, to explain what data is collected, how it is used, stored, and in which cases it may be transferred to third parties.

1.3. The App is intended for persons who have reached 18 years of age. By using the App, You confirm that You have reached the specified age.

2. What Data is Collected

2.1. Automatically collected technical data:

• IP address;
• device type, model, operating system and its version;
• device identifiers (IDFA, GAID or similar, if permitted);
• App version, interface language, time zone;
• session data: start and end times, duration, frequency of use;
• information about actions within the App (e.g., use of complaint features, errors, crashes);
• cookies and similar technologies (see Section 8 for details).

2.2. Data voluntarily provided by the User:

• text messages, photos, videos, and other content that the User exchanges with other Users;
• nickname (alias), if used;
• any other information that the User decides to disclose during communication.

2.3. Data obtained from third parties:

• if the User signs in through third-party services (e.g., Apple Sign In or Google Sign In), technical identifiers not containing personal information may be obtained.

2.4. The App does not require mandatory provision of full name, email address, phone number, or other direct identifiers for basic use. However, IP address and technical identifiers may be considered personal data under applicable law.

3. Purposes and Legal Bases for Data Processing

3.1. Collected data is used for the following purposes:

• Ensuring the functioning of the Service: message delivery, maintaining connections, identifying and resolving technical issues (basis — performance of a contract with the User, Art. 6(1)(b) GDPR, para. 5 part 1 Art. 6 of 152-FZ).
• Security and prevention of violations: protection against fraud, spam, hacking, malware distribution, as well as detection and suppression of illegal content, including child sexual abuse materials (CSAM/CSAE) (basis — legitimate interest of the Administration, Art. 6(1)(f) GDPR, part 1 Art. 6 of 152-FZ, as well as compliance with legal requirements).
• Compliance with the requirements of RF legislation and other applicable jurisdictions: log retention, provision of information to authorized bodies upon motivated requests (basis — legal obligation, Art. 6(1)(c) GDPR, para. 2 part 1 Art. 6 of 152-FZ).
• Service quality improvement and analytics: analysis of anonymized statistical data on feature popularity, failure rates, behavioral patterns (basis — legitimate interest, Art. 6(1)(f) GDPR).
• Marketing and advertising (if applicable): display of advertising materials in the App. Advertising may be personalized based on anonymized technical data; in this case, the User will be informed separately and may opt out of personalization.

3.2. By using the App, the User gives informed consent to the processing of data for the specified purposes, including the processing of technical data, as well as to the Administration's access to message content in cases provided for in Section 5 of this Policy.

4. Data Storage and Protection

4.1. The Administration takes necessary organizational and technical measures to protect data from unauthorized access, modification, disclosure, or destruction. Such measures include: encryption during data transmission (TLS/SSL), restriction of employee access, regular security system updates.

4.2. Retention periods:

• Technical logs (IP address, session times, device identifiers) are stored for the period necessary to ensure security and comply with legal requirements, but not less than 6 months from the last use of the App.
• Correspondence content (text, photos, videos) is not stored on the Administration's servers longer than technically necessary for message delivery, in order to ensure anonymity. However, in certain cases (e.g., upon receipt of a complaint, triggering of automatic filters, or a request from authorized bodies), the Administration may retain a copy of the message and associated metadata for the period necessary to conduct an investigation and/or comply with legal requirements.
• Data processed on the basis of consent is stored until consent is withdrawn, unless otherwise established by law.

4.3. Cross-border transfer. The Administration is located in the territory of the Russian Federation, and data processing is carried out primarily on servers located in the RF. However, to ensure the operation of the App, data may be transferred to servers located in other countries (including countries that do not provide an adequate level of protection according to the European Commission), if necessary for technical functioning (e.g., CDN, cloud services). By using the App, the User gives explicit consent to such cross-border transfer. The Administration takes reasonable measures to ensure the confidentiality of transferred data (e.g., concluding standard contractual clauses).

5. Transfer of Data to Third Parties

5.1. The Administration does not sell or transfer Users' personal data to third parties for their own marketing purposes.

5.2. Data may be transferred to the following categories of recipients:

• Government authorities: The Administration may transfer information (including correspondence content) to law enforcement agencies, courts, and other authorized bodies of the Russian Federation, as well as to competent authorities of foreign states if there are legal grounds (court decision, official request within the framework of international cooperation).
• Service providers: The Administration may engage third-party companies for technical support, analytics, cloud storage, and security. Such companies receive access only to the data necessary to perform their functions and are obliged to maintain confidentiality.
• Advertising networks and analytics platforms: If the App uses advertising, data may be transferred to advertising partners in anonymized form or as device advertising identifiers (IDFA/GAID) subject to the User's consent, if required by applicable law.

5.3. The Administration may disclose information if necessary to protect the rights, property, or safety of the Administration, Users, or third parties, as well as to investigate suspected fraud or other violations.

6. Use of Cookies and Similar Technologies

6.1. The App and its associated web pages may use cookies, web beacons, pixels, and similar technologies for authentication, saving settings, traffic analysis, and advertising effectiveness.

6.2. The User may manage cookie settings in their device or browser settings; however, disabling certain cookies may affect the App's functionality.

7. User Rights

7.1. The User has the right to:

• request information about the processed data (categories, purposes, sources, retention periods);
• demand clarification, blocking, or deletion of their data if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated processing purpose;
• withdraw consent to the processing of personal data at any time by sending a request to the email address specified in Section 10;
• object to data processing based on legitimate interest, if provided by applicable law;
• file a complaint with the supervisory authority for data protection (in the RF — Roskomnadzor, in the EU — the relevant supervisory authority of the country of residence).

7.2. Additional rights for residents of the European Economic Area (GDPR):

• right to data portability (Art. 20 GDPR);
• right to restriction of processing (Art. 18 GDPR);
• right to object to automated decision-making, including profiling (Art. 22 GDPR).

7.3. To exercise any of the listed rights, a written request must be sent to the email address specified in Section 10. The request must contain sufficient information to identify the User. The Administration undertakes to review the request within 30 calendar days, unless otherwise provided by law.

8. Processing of Minors' Data

8.1. The App is not intended for persons under 18 years of age. The Administration does not knowingly collect personal data of minors. If you become aware that a child has provided their data or is using the App, please contact us. Such data will be immediately deleted.

9. Changes to the Policy

9.1. The Administration reserves the right to make changes to this Policy unilaterally. The new version takes effect from the moment of its publication in the App or on the official website, unless otherwise specified.

9.2. Continued use of the App after changes are made constitutes the User's consent to the updated Policy. In case of material changes affecting the User's rights, the Administration may send an additional notification (e.g., via push notification or in-app banner).

10. Contacts

For all questions related to this Policy and data processing, You may contact the App's support service at: mosbar81@proton.me.

The Administration undertakes to respond to requests within a reasonable time, but no more than 30 days from receipt.