Privacy policy
What data is used when you visit the website, play demo games or contact us, why it is needed and how to exercise your rights.
1. Who processes your data
The Operator is sole proprietor A. S. Yunkov, OGRNIP 317502400031149. For personal data enquiries, contact yunkov@109px.ru.
This policy covers 109games.ru and its contact channels under Russian Federal Law No. 152-FZ on Personal Data. Visiting the website does not constitute consent to processing.
2. Enquiries and project discussions
We process the name or username, contacts, company information and correspondence you provide by email or Telegram to reply, prepare a proposal and discuss your project.
The grounds are steps towards and performance of a contract at your request, under Article 6(1)(5); business correspondence with client representatives, subject to their rights, under Article 6(1)(7); and legal obligations when handling personal data requests.
Where consent is needed, it is requested separately. Advertising mailings require prior consent.
3. Website operation and browser settings
The server receives your IP address, requested address, request time and browser information. The hosting service may retain technical logs to operate the website, diagnose errors and prevent abuse. The basis is the legitimate interest in website security, subject to visitors’ rights, under Article 6(1)(7) of Law No. 152-FZ.
Your browser stores interface, tutorial and access preferences and local game results for the session or until replaced or cleared. A service cookie is used to sign into private statistics.
You can clear or restrict these records in your browser settings; game results and preferences may reset.
4. Website and game statistics
Our own counters assess interest in services and demo performance: page and game opens, contact clicks and offer interactions. Bull Rush also reports starts, restarts, active play time, scores, distance and location progression.
The database retains totals by day, language and opening context, without individual events, IP addresses, names or contacts. Persistent visitor identifiers and screen recordings are not used. Hosting logs are processed separately.
Daily browser markers limit duplicate counts, without cookies or a personal identifier. Yandex Metrica and Session Replay are disabled; statistics are not sent to external analytics services.
5. Access and protection
Data is received, stored, used, corrected and deleted using automated tools and manually. Access is limited to what is necessary for the task. Disclosure to contractors requires a lawful basis and confidentiality; disclosure to public authorities requires a basis provided by law.
Hosting, Telegram and email services participate in processing under their own terms. This does not remove the Operator’s obligations concerning the data received.
Reports require authentication and event collection requires a secure connection. The Operator must ensure confidentiality and protection against unlawful access and loss.
6. Retention and deletion
Correspondence is kept until the enquiry and project discussion are complete; contract data is kept for performance and legally required document retention. Technical information is limited to website operation and security purposes; log retention depends on hosting settings.
Data must be destroyed within 30 days after its purpose is achieved or consent withdrawn, unless another lawful retention basis applies. Other deadlines follow Article 21 of Law No. 152-FZ. Relevant records and copies must be deleted, including those held by parties processing them on the Operator’s behalf.
7. Your rights
You may request information about the processing of your data, request correction, restriction or destruction where legally applicable, withdraw consent, and complain to Roskomnadzor or a court.
Email yunkov@109px.ru with your request and reply contact. Verification may be needed. Processing information is provided within 10 working days; an extension of up to 5 working days requires an explanation. Other requests follow statutory deadlines.
The current version is published on this page. Updating the policy does not replace consent where consent is required.