Account Data Processing Agreement
Last updated: 4 March 2026
Welcome to Imposter 3D: Online Horror!
PLEASE READ THIS AGREEMENT CAREFULLY.
I freely and voluntarily give my consent to IP (Individual Entrepreneur) Demkin Danila (Snow Bat) (“Operator”, “we”) to process my account data under the following terms.
1. What data we store and why
| Category | Specific data | Purpose | Retention |
|---|---|---|---|
| Identifiers | Auto-generated login (UID), nickname, Firebase UID | Authentication, display in matches | Until account deletion (nickname may remain in chat history) |
| Game progress | Level, currency, items, settings | Save and restore progress | Until account deletion |
| Technical data | Client version, device ID hash, last login time, device and connection logs | Security, anti-cheat, support | 6 months |
| Chat messages | Message text, reports, chat IDs | Moderation, rule enforcement | 6 months |
The login (UID) is generated automatically and cannot contain personal information. Users cannot set it manually.
2. Age and consent
- Under 14 (including users under 13 in the US per COPPA) – registration is prohibited. Gameplay is available in guest mode (quick chat only). Guest mode does not allow free text input. Creating an account requires verified parental consent.
- 14–18 – may create an account independently, but parental consent may be requested.
- 18+ – free registration.
Age is determined on first launch by the date of birth provided. Guest mode collects no personal data beyond the generated nickname and technical logs.
Note for US users (COPPA): We do not knowingly collect personal data from children under 13. If you are under 13, please do not use or register an account. Parents may contact us if they believe their child has provided personal data without consent, and we will promptly delete it.
Parental consent:
A parent or legal guardian may send an email to
snowbatstudio@gmail.com with subject “Parental Consent” including the child’s name (or nickname/UID), age, and a statement confirming permission to create an account.
3. Legal bases
- Your voluntary consent (this document).
- Performance of the service contract (providing the game account and features).
- Compliance with applicable data protection laws (GDPR, CCPA, LGPD, etc.).
4. Third-party processors
- Google Firebase – authentication, cloud storage, crash reporting.
- Firebase Analytics – anonymized technical analytics (device, OS, gameplay events).
- Photon PUN 2 – multiplayer and matchmaking.
- Advertising networks / SDKs – ads display, frequency capping, fraud prevention:
- Google AdMob
- Unity Ads
- AppLovin
- Vungle
- ironSource
- AdColony
- Chartboost
- Tapjoy
- Start.io
- Appodeal
- Bytedance / Pangle
- BigoAds
- Mintegral
- MyTarget (Mail.ru / VK)
- Apple (App Store advertising & distribution)
We do not sell or share your personal information. These providers receive only technical identifiers necessary to serve and measure ads. They may use such data under their own privacy policies.
4.1 International Data Transfers
International Data Transfers: Your data may be transferred to and processed in countries outside of your residence (including the United States and Russia) where our servers or partners (e.g., Google Firebase) are located. We rely on your consent and standard contractual safeguards for such transfers.
5. Retention and deletion
- All account data is deleted within 30 days after pressing “Delete Account”.
- Chat logs are deleted automatically after 6 months.
- Backups are retained for 7 days before secure deletion.
6. Your rights
You may request a copy of your data, correct it, delete your account, or withdraw consent at any time. Requests: snowbatstudio@gmail.com. Response time: up to 30 days. Data controller: Danila Demkin.
Complaints / Supervisory Authority
If you are located in the European Union, you have the right to lodge a complaint with your local data protection supervisory authority if you believe that our processing of your personal data infringes data protection law.
California (CCPA/CPRA): Under the CCPA, we do not "sell" your personal information for money. However, sharing technical identifiers with ad networks for personalized advertising may be considered "sharing" under California law. You may opt-out of personalized ads in your device settings.
7. Account deletion
- Menu: Online → Account → Account Settings
- Press Delete Account and confirm.
Or send an email to snowbatstudio@gmail.com with subject “Delete Account”.
8. Security
Data is transmitted via TLS 1.3; tokens are stored securely on Firebase; database access is restricted by IAM roles. The date, time, and version of this Agreement accepted are logged at account creation.
9. Changes
We will notify of material changes in-game or on our website at least 7 days before they take effect. Continued play means acceptance of the new terms.
10. Acceptance
Before account creation, users must check the following boxes:
- [ ] “I am 14 years or older / I have verified parental consent.”
- [ ] “I accept the License Agreement and Privacy Policy.”
- [ ] “I consent to the processing of my personal data in accordance with this Data Processing Agreement.”
- [ ] “I consent to the cross-border transfer of my data to the US and Russia to provide the game service.”
The “Create Account” button becomes active only after all required boxes are ticked. Users who do not agree may continue playing in guest mode without registration.
Contact Snow Bat
Location: Norilsk, Russian Federation