1. General Provisions

This Privacy Policy defines the procedure for processing and protecting personal data of users of the "Мне по силам" application (hereinafter referred to as the "Application").

By using the Application, you confirm your agreement with the terms of this Policy.

2. What Data We Collect

When using the Application, the following data may be collected:

2.1. Personal Data Provided by the User:

• Name and email address (during registration);
• Age and region of residence (when filling out the profile);
• Password for account access (stored in encrypted form);
• Additional profile information (at the user's discretion).

2.2. Health and Activity Data:

• Step count and distance (via Health Connect / Apple Health);
• Physical activity data synchronized from external services;
• User activity history in the application.

2.3. Automatically Collected Data:

• Unique device identifier (Device ID, Advertising ID);
• Device type, model, and operating system version;
• Application version;
• Language and regional settings of the device;
• IP address and internet connection information;
• Application usage time and function usage data;
• Technical logs and error information (to improve application performance).

2.4. Data We Do NOT Collect:

• Precise location (geolocation);
• Contacts and phone book;
• Photos and media files;
• Bank card data and payment information;
• Data from other applications on the device.

3. How We Use Your Data

We use your data exclusively for the following purposes:

3.1. Providing Core Application Features:

• Creating and managing user accounts;
• Tracking and displaying user activity;
• Generating rankings and achievements;
• Synchronizing data with Health Connect / Apple Health services;
• Providing personalized content and recommendations.

3.2. Improving Application Performance:

• Analyzing application feature usage;
• Fixing errors and technical issues;
• Optimizing application performance;
• Developing new features based on user feedback.

3.3. User Communication:

• Feedback and technical support;
• Notifications about important application updates (with user consent);
• Responding to user requests.

3.4. Security and Compliance:

• Ensuring data security;
• Preventing fraud and abuse;
• Compliance with legal requirements.

Important: We do NOT use your data for advertising or transfer it to third parties for advertising purposes.

4. Sharing Data with Third Parties

4.1. General Principles:

We do not sell or transfer your personal data to third parties for their commercial use. Your data is not used for advertising purposes.

4.2. Service Providers:

We may use third-party services to ensure the application's operation (hosting, cloud data storage, analytics). These providers are required to protect your data and use it only in accordance with our instructions:

• Cloud providers for data storage (in accordance with security requirements);
• Analytics service providers (only aggregated and anonymized data);
• Support and infrastructure service providers.

4.3. Health Service Integration:

The application integrates with Health Connect (Android) and Apple Health (iOS) to obtain physical activity data. This data is transferred only between your device and the specified services in accordance with their privacy policies.

4.4. Legal Requirements:

We may disclose your data only in the following cases:

• Upon lawful request from government authorities of the Russian Federation;
• To protect our rights and user safety;
• In case of change of control over the company (in case of merger or acquisition, users will be notified).

5. Data Storage and Protection

5.1. Security Measures:

We take all reasonable technical and organizational measures to protect user data from unauthorized access, modification, disclosure, or destruction:

• Data encryption during transmission (HTTPS/TLS protocol);
• Encryption of sensitive data at rest;
• Use of secure authentication and authorization methods;
• Regular security audits and system updates;
• Limiting access to personal data to authorized employees only;
• Regular data backups.

5.2. Data Storage Location:

User data is stored on servers located in the Russian Federation. When using cloud services, we ensure that providers comply with personal data protection legislation.

5.3. Data Retention Periods:

We store your personal data for the entire period of your use of the application and for 3 years after account deletion (unless longer retention is required by law). Technical logs and anonymized data may be stored longer for analytics and application improvement purposes.

5.4. Liability Limitations:

Despite the security measures taken, no method of data transmission over the internet or method of electronic storage is absolutely secure. We cannot guarantee absolute data security, but we commit to making every effort to protect it.

6. Use of Health Connect / Apple Health

6.1. Data Types:

The application only accesses the following health and activity data:

• Step count (Steps);
• Distance;
• Active minutes — if available.

6.2. User Consent:

Access to health data is granted only with your explicit consent. You can revoke access to this data at any time in the application settings or in your device settings.

6.3. Data Usage:

We use health data exclusively for:

• Calculating achievements and points in the application;
• Displaying activity statistics;
• Generating rankings and competitions (without disclosing personal data).

6.4. Data Transfer:

Health data is not transferred to third parties and is used only within the application's functionality. Data is synchronized with our servers to ensure the application works on all your devices.

6.5. Third-Party Service Policies:

The use of data through Health Connect or Apple Health is also governed by the privacy policies of these services:

• Health Connect — privacy policy is available in the Health Connect app settings on your Android device;
• Apple Health — detailed privacy information is available in the "Privacy" section in the "Health" app settings on your iOS device, as well as on the Apple Privacy Policy website.

7. User Rights

7.1. Right to Access:

You have the right to obtain information about what personal data we store about you and receive a copy of this data. To do this, contact us at support@mneposilam.ru

7.2. Right to Rectification:

You can change or update your personal data at any time in the application settings or by sending a request to support.

7.3. Right to Deletion:

You have the right to delete your account and all personal data in the following ways:

• Through the "Security" section in the application settings;
• By sending a request to support@mneposilam.ru with your email address.

Account and personal data deletion is performed within 10 business days from the receipt of the request. After deletion, data recovery is not possible.

7.4. Right to Data Portability:

You have the right to receive your data in a structured, commonly used, and machine-readable format. To request data, contact support.

7.5. Right to Withdraw Consent:

You can withdraw your consent to the processing of personal data at any time by disabling the corresponding features in the application settings or deleting your account. Withdrawal of consent does not affect the lawfulness of data processing that was carried out before the withdrawal of consent.

7.6. Right to Object:

You have the right to object to the processing of your personal data for certain purposes. To exercise this right, contact support.

7.7. Right to Lodge a Complaint:

If you believe that your rights have been violated, you have the right to lodge a complaint with the authorized data protection authority in your country or region.

8. Cookies and Similar Technologies

8.1. Use of Cookies:

When using the web version of the application or website, we may use cookies and similar technologies for:

• Ensuring core functionality;
• Saving your settings and preferences;
• Analyzing service usage (anonymized data).

8.2. Cookie Management:

You can configure your browser to reject cookies, however, this may limit the application's functionality.

9. Children's Data Protection

Our application is not intended for children under 13 years of age (or the age of consent in your jurisdiction). We do not knowingly collect personal data from children under 13 years of age.

If we learn that we have collected personal data from a child under 13 years of age, we will immediately delete this data. If you are a parent or guardian and believe that your child has provided us with personal data, please contact us at support@mneposilam.ru

10. International Data Transfer

User data is stored and processed on servers located in the Russian Federation. If it is necessary to transfer data to other countries, we will ensure compliance with personal data protection legislation and apply appropriate security measures.

For users from the European Union: when transferring data outside the EEA, we ensure an adequate level of data protection in accordance with GDPR requirements.

11. Use of Analytics

We may use analytics services to collect aggregated and anonymized information about application usage. This data helps us improve functionality and user experience. Analytics data does not contain information that can identify a specific user.

12. Advertising

Currently, the application does not contain advertising and does not use user personal data for advertising purposes. If we plan to add advertising in the future, we will notify users and update this Privacy Policy.

13. Policy Changes

We may update this Privacy Policy from time to time. We will notify you of significant changes in one of the following ways:

• Through a notification in the application;
• By email (if you have provided an address);
• By publishing an updated version on our website.

The current version of the Policy is always available at: https://mneposilam.ru/support/privacy.html

The date of the last update is indicated at the beginning of this document. By continuing to use the application after changes are made, you agree to the updated Policy.

14. Applicable Legislation

This Privacy Policy has been developed in accordance with:

• Federal Law No. 152-FZ "On Personal Data" (Russian Federation);
• General Data Protection Regulation (GDPR) for users from the European Union;
• Google Play Privacy Policy and Google requirements.