PRIVACY POLICY
for the Kolobok.run website and the “Kolobok” mobile application
Last updated: September 26, 2026
1. General Provisions
1.1 This Privacy Policy (hereinafter — the “Policy”) applies to all information that the owner of the Kolobok.run website (hereinafter — the “Website”) and the “Kolobok” mobile application (hereinafter — the “Application”) may obtain about the user during their use of the Website and/or the Application.
1.2 Use of the Website, installation, launch or use of the Application means the user’s unconditional consent to this Policy and the terms of processing of their personal information set out herein. If the user disagrees with these terms, the user must refrain from using the Website and delete the Application.
1.3 This Policy is drafted in accordance with applicable data protection laws, including, where applicable, the General Data Protection Regulation (EU) 2016/679 (GDPR) and other relevant local legislation.
2. Categories of Personal Information Processed
2.1 For the purposes of this Policy, “user personal information” means:
2.1.1 Information provided by the user voluntarily:
Location data (key category):
2.3 The Website and the Application generally do not verify the accuracy of personal information provided by users and do not monitor their legal capacity. However, the Website and the Application proceed from the assumption that the user provides accurate and sufficient personal information and keeps it up to date.
3. Special Conditions for Processing Location Data
3.1 The key function of the Application is a geo-tracker, recording the user’s routes, navigation and participation in online activities, which is based on the processing of location data.
3.2 Public nature of data. The Application supports an online broadcast feature, under which the user’s route and location data may be transmitted to publicly accessible servers. Any third party with access to such servers may view, obtain or use this data.
3.3 The user understands and confirms that:
4. Purposes of Collecting and Processing Personal Information
4.1 The Website and the Application collect and store only those personal data that are necessary for providing and rendering services (performing agreements and contracts with the user).
4.2 The Website and the Application may use the user’s personal information for the following purposes:
4.2.1 providing the user with the core functions of the Application (route recording, navigation, sports data analysis, online broadcast);
4.2.2 identifying a party within the framework of agreements and contracts;
4.2.3 communicating with the user, including sending notifications, requests and information related to the use of the Website and the Application, the provision of services, as well as processing user requests and applications;
4.2.4 improving quality, usability, and developing services;
4.2.5 targeting advertising materials;
4.2.6 conducting statistical and other research based on anonymized data.
5. Conditions for Processing Personal Information and Its Transfer to Third Parties
5.1 The Website and the Application store users’ personal information in accordance with the internal regulations of specific services.
5.2 The confidentiality of the user’s personal information is maintained, except in cases where the user voluntarily provides information about themselves for public access to an unlimited number of persons. When using the Application’s online broadcast feature, the user agrees that a certain part of their personal information (including route and location data) becomes publicly available.
5.3 The Website and the Application have the right to transfer the user’s personal information to third parties in the following cases:
5.3.1 the user has expressed consent to such actions;
5.3.2 the transfer is necessary within the framework of the user’s use of a particular service or for providing a service to the user;
5.3.3 the transfer is provided for by applicable law within the procedure established by law;
5.3.4 such transfer occurs within the framework of a sale or other transfer of business (in whole or in part), with all obligations to comply with the terms of this Policy with respect to the received personal information passing to the acquirer;
5.3.5 for the purpose of protecting the rights and legitimate interests of the Website, the Application or third parties in cases where the user violates the User Agreement of the services.
5.4 The transfer of location data to public servers is carried out at the user’s discretion when activating the relevant features of the Application and is governed by clause 3.2 of this Policy.
5.5 When processing users’ personal data, the Website and the Application are guided by applicable data protection laws and regulations.
6. User Rights
6.1 The user has the right at any time to:
6.1.1 change (update, supplement) the personal information they have provided or any part thereof, as well as its confidentiality parameters;
6.1.2 withdraw consent to the processing of personal data (including by deleting the Application or disabling the relevant features);
6.1.3 request the deletion of their personal data.
6.2 After withdrawal of consent, the Website and the Application cease processing the relevant personal data, except in cases where processing is necessary to comply with legal requirements or protect legitimate interests.
7. Measures Applied to Protect Users’ Personal Information
The Website and the Application take necessary and sufficient organizational and technical measures to protect the user’s personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties.
8. Changes to the Privacy Policy. Applicable Law
8.1 The Website and the Application have the right to make changes to this Privacy Policy. When changes are made, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment it is posted, unless otherwise provided by the new version of the Policy.
8.2 This Policy and the relations between the user and the Website/Application arising in connection with the application of the Privacy Policy shall be governed by the applicable law of the user’s jurisdiction, unless otherwise required by mandatory local legislation.
9. Special Notice (Location Data)
Before installing or using the “Kolobok” Application, please read the following:
for the Kolobok.run website and the “Kolobok” mobile application
Last updated: September 26, 2026
1. General Provisions
1.1 This Privacy Policy (hereinafter — the “Policy”) applies to all information that the owner of the Kolobok.run website (hereinafter — the “Website”) and the “Kolobok” mobile application (hereinafter — the “Application”) may obtain about the user during their use of the Website and/or the Application.
1.2 Use of the Website, installation, launch or use of the Application means the user’s unconditional consent to this Policy and the terms of processing of their personal information set out herein. If the user disagrees with these terms, the user must refrain from using the Website and delete the Application.
1.3 This Policy is drafted in accordance with applicable data protection laws, including, where applicable, the General Data Protection Regulation (EU) 2016/679 (GDPR) and other relevant local legislation.
2. Categories of Personal Information Processed
2.1 For the purposes of this Policy, “user personal information” means:
2.1.1 Information provided by the user voluntarily:
- data entered when filling out feedback forms on the Website (name, contact details, message content);
- account data created when registering in the Application.
- IP address, cookie information, information about the user’s browser (or other program used to access the services), time of access, address of the requested page.
Location data (key category):
- precise geolocation (GPS coordinates);
- tracking data (coordinate arrays, speed, distance, timestamps);
- if background operation is permitted, location data may be collected while the Application is closed or inactive;
- in accordance with the Application’s functionality, tracking data may be transmitted to publicly accessible servers, where it may be viewed by third parties.
- device ID or other identifiers.
- statistical information about the use of the Application.
2.3 The Website and the Application generally do not verify the accuracy of personal information provided by users and do not monitor their legal capacity. However, the Website and the Application proceed from the assumption that the user provides accurate and sufficient personal information and keeps it up to date.
3. Special Conditions for Processing Location Data
3.1 The key function of the Application is a geo-tracker, recording the user’s routes, navigation and participation in online activities, which is based on the processing of location data.
3.2 Public nature of data. The Application supports an online broadcast feature, under which the user’s route and location data may be transmitted to publicly accessible servers. Any third party with access to such servers may view, obtain or use this data.
3.3 The user understands and confirms that:
- location data constitutes personal information that can be linked to a specific individual and is highly sensitive from a privacy perspective;
- enabling the tracking and online broadcast features in the Application constitutes explicit consent to the processing of location data in the manner described in this Policy, including disclosure to an unlimited number of persons;
- the user may withdraw consent at any time by disabling the tracking or online broadcast feature in the Application settings.
4. Purposes of Collecting and Processing Personal Information
4.1 The Website and the Application collect and store only those personal data that are necessary for providing and rendering services (performing agreements and contracts with the user).
4.2 The Website and the Application may use the user’s personal information for the following purposes:
4.2.1 providing the user with the core functions of the Application (route recording, navigation, sports data analysis, online broadcast);
4.2.2 identifying a party within the framework of agreements and contracts;
4.2.3 communicating with the user, including sending notifications, requests and information related to the use of the Website and the Application, the provision of services, as well as processing user requests and applications;
4.2.4 improving quality, usability, and developing services;
4.2.5 targeting advertising materials;
4.2.6 conducting statistical and other research based on anonymized data.
5. Conditions for Processing Personal Information and Its Transfer to Third Parties
5.1 The Website and the Application store users’ personal information in accordance with the internal regulations of specific services.
5.2 The confidentiality of the user’s personal information is maintained, except in cases where the user voluntarily provides information about themselves for public access to an unlimited number of persons. When using the Application’s online broadcast feature, the user agrees that a certain part of their personal information (including route and location data) becomes publicly available.
5.3 The Website and the Application have the right to transfer the user’s personal information to third parties in the following cases:
5.3.1 the user has expressed consent to such actions;
5.3.2 the transfer is necessary within the framework of the user’s use of a particular service or for providing a service to the user;
5.3.3 the transfer is provided for by applicable law within the procedure established by law;
5.3.4 such transfer occurs within the framework of a sale or other transfer of business (in whole or in part), with all obligations to comply with the terms of this Policy with respect to the received personal information passing to the acquirer;
5.3.5 for the purpose of protecting the rights and legitimate interests of the Website, the Application or third parties in cases where the user violates the User Agreement of the services.
5.4 The transfer of location data to public servers is carried out at the user’s discretion when activating the relevant features of the Application and is governed by clause 3.2 of this Policy.
5.5 When processing users’ personal data, the Website and the Application are guided by applicable data protection laws and regulations.
6. User Rights
6.1 The user has the right at any time to:
6.1.1 change (update, supplement) the personal information they have provided or any part thereof, as well as its confidentiality parameters;
6.1.2 withdraw consent to the processing of personal data (including by deleting the Application or disabling the relevant features);
6.1.3 request the deletion of their personal data.
6.2 After withdrawal of consent, the Website and the Application cease processing the relevant personal data, except in cases where processing is necessary to comply with legal requirements or protect legitimate interests.
7. Measures Applied to Protect Users’ Personal Information
The Website and the Application take necessary and sufficient organizational and technical measures to protect the user’s personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties.
8. Changes to the Privacy Policy. Applicable Law
8.1 The Website and the Application have the right to make changes to this Privacy Policy. When changes are made, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment it is posted, unless otherwise provided by the new version of the Policy.
8.2 This Policy and the relations between the user and the Website/Application arising in connection with the application of the Privacy Policy shall be governed by the applicable law of the user’s jurisdiction, unless otherwise required by mandatory local legislation.
9. Special Notice (Location Data)
Before installing or using the “Kolobok” Application, please read the following:
- The Application is capable of recording your precise location and, when the relevant feature is enabled, transmitting it to public servers;
- location data on public servers may be viewed, downloaded or used by third parties;
- for safety reasons, it is recommended to take a balanced approach to enabling the online broadcast feature;
- you may disable the location permission at any time in the Application settings or in the device’s system settings.