Account Data Processing Agreement
Last updated: 16 July 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

The login (UID) is generated automatically and cannot contain personal information. Users cannot set it manually.

2. Age and consent

• Under 14 – registered accounts and free text chat are not available. Limited gameplay may be available in Guest mode with quick chat only.
• 14–18 – an account may be created only where the user has the legal capacity or authorization required by the contract law of the user's country. The GDPR age of consent for a particular processing operation is not a universal account age.
• 18+ – free registration.

Age is determined through the age information requested by the Product. Guest mode is not anonymous: an IP address, Device or app-instance identifier, and another persistent technical identifier may still be personal data.

EU/EEA: Article 8 GDPR applies only where processing is based on consent for an information society service offered directly to a child. The threshold is 16 unless the applicable Member State has set a lower age between 13 and 15. Contractual capacity is assessed separately under national law.

United States (COPPA): IP addresses, advertising identifiers, Device identifiers, and other persistent identifiers may be personal information even in Guest mode. We do not currently operate a child-account flow in which a checkbox, app-store credential, or unverified email response is accepted as verifiable parental consent. A U.S. user under 13 therefore may not create a registered account or use free text chat. Advertising or non-essential analytics SDKs must not be activated for a known under-13 user unless a specific COPPA exception applies or the required direct notice and verifiable parental consent have been completed. Separate verifiable parental consent is required for targeted advertising and other non-integral third-party disclosures.

Parent inquiries: A parent or legal guardian may contact snowbatstudio@gmail.com to ask a question or request deletion of a child's information. An ordinary email does not by itself authorize account creation, targeted advertising, or disclosure of a child's information to advertising networks.

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 providers

• Google Firebase – authentication, cloud storage, crash reporting.
• Firebase Analytics – pseudonymous 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
  • Liftoff Monetize (formerly Vungle)
  • ironSource
  • Digital Turbine (formerly AdColony)
  • Chartboost
  • Tapjoy
  • Start.io
  • Bytedance / Pangle
  • BigoAds
  • Mintegral
  • MGL MY.COM (CYPRUS) LIMITED — myTarget
  • InMobi
  • zMaticoo
  • Yandex Mobile Ads and Yandex AppMetrica components
  • Apple (App Store advertising & distribution)

We do not sell personal information for money. The listed providers may receive technical identifiers needed to provide, secure, and measure their services and may process them under their own privacy policies. Every provider that receives user data from the Product is required to provide the same or equivalent protection described in the Privacy Policy and required by applicable law and App Store rules.

4.1 International Data Transfers

Your data may be transferred to and processed in countries outside your residence (including the United States and Russia) where relevant services, such as Google Firebase, operate. Where required, we rely on the separate cross-border-transfer consent shown below. Where another transfer mechanism applies, the transfer is made under the applicable safeguard or exception permitted by law; this Agreement does not claim that one identical mechanism applies to every provider.

5. Retention and deletion

• Self-service deletion removes the active account, profile, progress, friends, and other user-generated Content controlled by the Operator immediately. It does not delete chat messages or history and related report, moderation, and security records before their 6-month retention period expires. Email deletion requests are completed within 30 days.
• Chat messages and history, together with related reports and moderation and security records, are retained for 6 months from each message, including after account deletion, for moderation, service security, investigation of abuse or suspected crimes, preservation of evidence, and responses to lawful requests. Account deletion does not restart the 6-month period.
• Backups of Data otherwise deleted may remain for up to 7 days; this does not replace a specific statutory retention period.

Access to retained chat history and related records is restricted, and these records are not used for advertising or personalization. After 6 months, they are deleted or irreversibly anonymized unless a specific legal hold, binding order, or applicable law requires a particular record to be retained longer. We also delete, return, or notify and instruct processors and other Product Data recipients to delete associated Data as appropriate, subject to the same limited exception.

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

1. Menu: Online → Account → Account Settings
2. Press Delete Account and confirm.

Or send an email to snowbatstudio@gmail.com with subject “Delete Account”.

8. Security

Data is transmitted using HTTPS/TLS where supported by the relevant service; tokens are handled through Firebase authentication; database access is restricted by access controls and service roles.
The date, time, and version of this Agreement accepted are logged at account creation.

9. Changes

We will notify you of material changes in-game or on our website before they take effect. Continued play does not constitute consent to a new optional processing purpose; where new consent is required, we will request a separate affirmative choice before that processing begins.

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

snowbatstudio@gmail.com

Location: Norilsk, Russian Federation