Privacy Policy of the PleinAir application

Effective date: February 12, 2026

1. DEFINITIONS
“Law” — primarily Federal Law of the Russian Federation No. 152-FZ “On Personal Data” and other
applicable acts of the Russian Federation; secondarily — applicable international standards,
including the GDPR for users located in the EEA (where grounds for its applicability exist).
“Operator” — the person who independently organizes and/or carries out the processing of personal
data: Alexey Pavlov (Right Holder of the Mobile Application).
“Mobile Application” — software for Android (with all add-ons and updates) distributed through app
stores (e.g., Google Play).
“User” — an individual who has installed and uses the Mobile Application.
“Personal Data” — information relating directly or indirectly to a specific or identifiable User (
personal data subject).
“Processing of Personal Data” — any action (operation) or set of actions with personal data (
collection, recording, storage, updating, use, deletion, etc.).
“Technical Data” — information that may be generated automatically during use of the application (
e.g., device/OS type, application events, crash data, service identifiers), if used to ensure
operability and security.

2. SCOPE OF THIS POLICY

2.1. This Policy applies to personal data that the Operator receives from the User or generates when
the User uses the Mobile Application.

2.2. By installing and using the Mobile Application, the User confirms that they have read this
Policy and agrees to the terms of personal data processing to the extent necessary for the operation
of the application.

2.3. If the User does not agree with the terms of this Policy, they must stop using the Mobile
Application and delete it.

3. LIST OF PROCESSED DATA
The Operator may process the following data (depending on which features the User uses):

3.1. Data for registration and login:

Telegram user id (if the User chooses login/registration via the Telegram bot).

The Telegram user id is not intended to be displayed to other users in the application interface.

3.2. Profile data voluntarily provided by the User:

- name/nickname (display name of the profile);

- city/region;

- profile description;

- preferred drawing techniques;

- images: avatar and portfolio images (at the User’s option);

- information about places/spots for drawing, if the User creates/saves them.

3.3. Location data (at the User’s choice):

- geolocation/point on the map (precise or approximate — depending on the User’s actions and
permissions).

3.4. Telegram username (at the User’s option):

Telegram username (e.g., @username) may be offered for saving during registration via Telegram (the
User may agree or refuse), and/or added/removed by the User in the “Edit profile” section.

4. PURPOSES OF PROCESSING
The Operator processes personal data for the following purposes:

4.1. registration, authorization, and maintaining the User account;

4.2. providing the application functionality (profile, search, displaying meetups/events, maps and
points);

4.3. displaying the User profile to other users within the application logic (social features);

4.4. enabling communication via Telegram: by pressing a button in the application, the User is
redirected to Telegram;

4.5. ensuring security, preventing abuse, technical diagnostics, and fixing errors;

4.6. processing User support requests.

5. THIRD-PARTY ACCESS AND EXTERNAL SERVICES

5.1. App stores. Distribution of the Mobile Application may be carried out through app stores (e.g.,
Google Play). Data processing by such services is performed under their own rules and privacy
policies.

5.2. Telegram. Telegram may be used for communication among participants and for contacting between
users. The transition to Telegram is initiated by the User. Data processing in Telegram is governed
by Telegram’s policy.

5.3. The Operator does not sell users’ personal data and does not transfer Telegram user id to third
parties for purposes unrelated to the operation of the application, except in cases expressly
required by law.

6. STORAGE PROCEDURE AND LOCALIZATION

6.1. Users’ personal data is stored and processed using databases located within the territory of
the Russian Federation (localization).

6.2. Storage period:

- while the account is active and the User uses the application;

- or until the User deletes the account;

- or until the account is deleted due to prolonged inactivity (e.g., if the User has not authorized in
the application for more than 1 year — the account and data may be deleted).

6.3. Account deletion: when selecting “Settings → Delete account”, the User’s data is deleted from
the application/server within 48 hours, except where retaining a minimal amount of data is required
by law or to protect the rights and legitimate interests of the Operator (e.g., when reviewing a
complaint/abuse) — for the minimum necessary period.

7. USER RIGHTS
The User has the right to:

7.1. obtain information about the processing of their personal data;

7.2. request correction of personal data, its blocking, or destruction where grounds exist;

7.3. withdraw consent to processing (if processing is based on consent);

7.4. delete the account and data via the application interface;

7.5. submit a request to the Operator using the contacts specified below.

8. SUBMISSION OF COMPLAINTS AND REQUESTS

8.1. Requests regarding personal data are sent to the e-mail: a9633238@gmail.com

8.2. The User also has the right to contact the authorized supervisory authority for the protection
of personal data subjects’ rights in the manner prescribed by law.

9. PERSONAL DATA PROTECTION MEASURES

9.1. The Operator takes reasonable organizational and technical measures to protect personal data
from unauthorized access, alteration, disclosure, or destruction.

9.2. The User understands that data transmission over the Internet cannot be guaranteed as
absolutely secure and accepts the risk associated with transmitting data over the Internet.

10. ACCESS BY MINORS

10.1. The Mobile Application is intended for persons 18+.

11. USERS IN THE EEA (GDPR)

11.1. If the User is located in the EEA and the GDPR is applicable to the processing, the Operator
provides the information required by Articles 13–14 of the GDPR (including: purposes, legal bases,
storage periods, data subject rights, contacts).

11.2. The main legal bases for processing may include: performance of a contract (providing the
application functionality), consent (e.g., to specify a Telegram username or geolocation),
legitimate interests (security and abuse prevention) — depending on the specific processing
operation.

12. ADVERTISING PLACEMENT

12.1. The Operator may place advertising materials in the Mobile Application (if such functionality
is предусмотрена).

12.2. Users are prohibited from placing advertising and spam in the application — this is regulated
by the Terms of Use.

13. DISCLAIMER OF WARRANTIES AND LIMITATION OF LIABILITY
The Right Holder, Controller, or Developer does not guarantee or represent that there will be no
failures or errors when using the Mobile Application, and you agree that the Right Holder,
Controller, or Developer may disable/delete/modify the Mobile Application for an indefinite period,
suspend the operation of the Mobile Application at any time, or otherwise restrict or block access
to the Application without prior notice.
You expressly agree that you alone bear all risks associated with your use (or inability to use) the
Mobile Application, as well as any other activity in relation to the Mobile Application. All content
provided to you within the Mobile Application is provided “as is” and “as available” without any
express or implied warranties, including all implied warranties of merchantability, fitness for a
particular purpose, title, and non-infringement. Since some jurisdictions do not allow the exclusion
of implied warranties, the above exclusion of implied warranties may not apply to you.
You agree that, unless otherwise provided by applicable law, the Right Holder, Controller, or
Developer is not responsible for ensuring uninterrupted access to content and is also not liable in
cases where content becomes unavailable for downloading, re-downloading, or other use.
Under no circumstances shall the Right Holder, Controller, or Developer, its directors, officers,
employees, affiliates, agents, contractors, or licensors be liable for any direct, indirect,
incidental, punitive, actual, or consequential damages related to your use of the Mobile Application
and/or content, as well as for any other claims in any way related to your use of the Mobile
Application and/or content, including, without limitation, errors or omissions in any content,
losses and damages of any kind incurred as a result of the use of any content posted, transmitted,
or otherwise made available through the Mobile Application, even if advised of the possibility of
such damages. Since some countries, states, or jurisdictions do not allow the exclusion or
limitation of liability for consequential or incidental damages, in such countries, states, or
jurisdictions the liability of the Right Holder, Controller, or Developer shall be limited to the
extent permitted by law.
The Right Holder, Controller, or Developer uses reasonable efforts to protect information provided
by you in connection with the use of the Mobile Application, but you agree that you provide such
information at your own risk, and hereby release the Right Holder, Controller, or Developer from any
liability to you for loss of data and from any other liability related to this information.
The Right Holder, Controller, or Developer does not represent or warrant that the service will be
fully protected against data loss, corruption, attacks, viruses, interference, hacking, or other
security breaches, and you hereby release the Right Holder, Controller, or Developer from any
liability related to these breaches. You are responsible for creating backup copies of information
contained in your system, including all content obtained through the Mobile Application.
The Right Holder, Controller, or Developer is not responsible for data transmission fees that may be
charged to you when using the Mobile Application.

14. FINAL PROVISIONS

14.1. The current version of the Policy is available at:
RU: https://raw.githubusercontent.com/AlexeyJarlax/Privacy-Policy/refs/heads/main/Pleinair_PP_RU
EN: https://raw.githubusercontent.com/AlexeyJarlax/Privacy-Policy/refs/heads/main/Pleinair_PP_EN

14.2. The Policy may be translated into foreign languages. In case of discrepancies, the
Russian-language version prevails.

14.3. This version of the Policy is effective as of “12” February 2026.

14.4. The Operator has the right to amend this Policy. The User undertakes to independently monitor
the актуальная version.

15. APPLICABLE LAW

15.1. This Policy is drafted in accordance with the legislation of the Russian Federation, including
152-FZ “On Personal Data”, and also taking into account the requirements for localization of
personal data databases (242-FZ) and, where applicable, the GDPR.