PRIVACY POLICY

Shablon mobile application · Version of 5 September 2026

This Privacy Policy explains what personal information the Shablon mobile application (the "App") collects, why we collect it, who we share it with, how long we keep it, and what you can do about it. It is written to be read by you, not by lawyers.

Please read Section 3 carefully. It explains where the App is offered, which law governs it, and where your information is stored.

1. Who we are

The App is operated by:

In this Policy, "we", "us" and "our" mean the Operator; "you" means the person using the App. Where this Policy uses the word "Operator", it refers to the role that in some other countries is called a "data controller".

2. What this Policy covers

2.1. This Policy covers the App, the website https://shablon.app and the servers that support them.

2.2. It does not cover services operated by other companies under their own terms — in particular the App Store, Google Play, RuStore, and the payment providers used to process your payment. When you buy a subscription through an app store, that store collects and processes your payment information under its own privacy policy, and we never see your full card details. Please read those policies separately.

2.3. It also does not cover anything you choose to share with another person through the App. If you invite a partner into a shared deck, a pair or an online room, the content you post there becomes visible to that person. That is the purpose of the feature, and we cannot un-share it for you.

3. Where the App is offered, and which law applies

3.1. The App is developed, operated and directed primarily at users in the Russian Federation and the CIS countries. Its content, interface and support are provided in Russian, prices are set in Russian roubles, and customer support operates on Moscow time.

3.2. The App is distributed through international app stores and may therefore be downloaded in other countries. We do not target our services at, advertise in, or tailor our content or pricing to users in the European Economic Area or the United Kingdom, and the App being technically available for download in a country does not mean it is offered to that market.

3.3. Our processing of personal information is governed by the law of the Russian Federation, principally Federal Law No. 152-FZ of 27 July 2006 "On Personal Data". Our notification of personal data processing is registered with the Russian data protection authority (Roskomnadzor) under registration number 124994/77 of 19 August 2026.

3.4. We do not claim compliance with the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA/CPRA) or similar laws of other countries, and this Policy should not be read as making such a claim. If you are subject to one of those laws and require a service that operates under it, the App is not the right product for you.

3.5. Regardless of where you live, we will answer requests to access, correct or delete your information as described in Section 9. We extend that as a matter of practice, not because a particular foreign law obliges us to.

4. Information we collect

4.1. We collect the following, and nothing beyond it:

4.2. We never receive or store your full card number, its security code (CVC/CVV) or your online banking credentials. Those are entered on the payment provider’s own secure page. The card fingerprint we receive is a one-way value that lets us tell whether a card has already been used for a free trial; it cannot be turned back into a card number.

4.3. We do not collect special categories of information such as health, religion, political views or biometric data, and we ask you not to put such information into the App. We do not collect precise location data.

4.4. Every profile field is optional. You can use the App fully without filling in any of them.

5. How we use your information

5.1. We do not sell your personal information, and we never share the content you create — your answers, messages, photos, decks or shared history — for advertising. We do, however, use the Meta (Facebook) software development kit to measure how well our marketing works. It reports certain actions you take in the App to Meta. Section 13 sets out exactly what is sent, what Meta does with it, and how to limit it.

5.2. We do not make decisions about you by purely automated means that produce legal effects or similarly significant consequences for you.

6. Who we share your information with

6.1. We share information only with the service providers listed below, only to the extent they need it to do their job for us, and only under contracts that require them to keep it confidential. We remain responsible to you for what they do with it.

6.2. We may also disclose information to public authorities where we are required to do so by Russian law, for example in response to a lawful and reasoned request.

6.3. If our business is ever transferred to another person, your information may transfer with it. We will tell you in the App before that happens.

7. Where your information is stored

7.1. Your information is stored on servers located in the Russian Federation (Yandex Cloud, region ru-central1). This applies to every user of the App, wherever you live. Russian law requires us to keep the personal data of Russian citizens in databases located in Russia, and we operate a single infrastructure for all users.

7.2. If you are outside the Russian Federation, this means your information leaves your country and is stored in a country whose data protection laws are different from your own and which your government may not regard as providing an equivalent level of protection. Russian authorities may be able to access data stored in Russia under Russian law. We are telling you this plainly so that you can make an informed choice about using the App.

7.3. Some of the companies listed in Section 6 are located in the United States and Ireland. A limited set of information — push tokens, device and advertising identifiers, subscription data and in-app events — is sent to them for the specific purposes described in that Section. Unlike our other providers, Meta does not act solely on our instructions: it uses the data it receives for its own purposes as well.

7.4. If you are not comfortable with your information being stored in the Russian Federation, please do not create an account. If you already have one, you can ask us to delete it as described in Section 9.

8. How long we keep your information

8.1. When a retention period ends, we delete the information or strip it of anything that could identify you.

8.2. One honest caveat about account deletion: a small set of anti-abuse records survives it. When you delete your account we keep the device identifier and the card fingerprint that were used to claim a free trial, so that the same device or card cannot claim the trial again by creating a new account. Those records are not linked to your name, e-mail or content and are never used to identify you for any other purpose. We also keep payment and accounting records for the 5 years Russian law requires.

9. Your choices and how to use them

9.1. Whatever country you are in, you can ask us to:

— tell you what information we hold about you and give you a copy of it;

— correct anything that is wrong or out of date;

— delete your account and the information associated with it, subject to the caveat in clause 8.2;

— withdraw a consent you previously gave, including consent to marketing messages;

— stop sending you marketing messages, without affecting your subscription or access to the App.

9.2. The quickest way to reach us is by e-mail to brandmynameis3@mail.ru from the address associated with your account. We aim to reply within 10 business days. There is no charge for any of this.

9.3. You can also do several things yourself, without contacting us: edit or clear any profile field in the App; delete content you have posted; turn push notifications off in your device settings; cancel your subscription and stop automatic renewal under "Settings → Subscription" in the App, or in your app store account if you subscribed through a store.

9.3.1. To limit advertising measurement specifically: on iOS, go to Settings → Privacy & Security → Tracking and turn off permission for Shablon; on Android, go to Settings → Privacy → Ads and delete or reset your advertising ID. Doing so does not affect your subscription or any feature of the App.

9.4. Deleting your account is permanent. Your decks, answers, messages, photos and shared history cannot be recovered afterwards, so please export or save anything you want to keep first.

9.5. If you are unhappy with how we have handled your information, write to us first — most things are quicker to fix that way. You may also complain to Roskomnadzor, the Russian data protection authority, or bring a claim before the Russian courts.

10. How we protect your information

10.1. We take the following measures, among others: all traffic between the App and our servers is encrypted in transit (TLS); your photos and media are stored in a private bucket and served only through short-lived signed links; passwords and secrets are stored only as irreversible hashes; access to production data is restricted to named individuals and protected by multi-factor authentication; administrator actions and system events are logged; and we take and test backups.

10.2. No system is perfectly secure, and we do not promise that ours is. If a security incident affects your information, we will notify the Russian data protection authority within the deadlines set by Russian law and will inform you where the incident is likely to affect you.

10.3. Please help us: use a unique e-mail address, keep access to it secure, and do not share your account with anyone.

11. Children

11.1. The App is rated 16+ and is intended for people aged 16 and over. We do not knowingly collect information from anyone under 16.

11.2. If you are between 16 and 18, you should use the App and make any purchase with the knowledge and agreement of your parent or guardian, unless you are paying with money you are entitled to manage yourself.

11.3. If you are a parent or guardian and believe your child under 16 has given us information, write to brandmynameis3@mail.ru and we will delete it.

12. Payments and app stores

12.1. Depending on where you are and how you subscribe, your payment is handled either by an app store (App Store, Google Play or RuStore) or by our Russian payment provider. In both cases the card details are handled by them, not by us.

12.2. Subscriptions renew automatically until cancelled. What we charge, how often, and how to cancel are set out on the subscription screen before you pay, and in our Terms at https://shablon.app/offer.

12.3. If you subscribed through an app store, cancellations and refunds are handled by that store under its rules. We will help you find the right screen if you ask.

13. Analytics, advertising measurement and tracking

13.1. AppMetrica. We use AppMetrica, a Russian analytics service, to understand how the App is used — which screens are opened, which features are used, where people get stuck, and whether a purchase succeeded. This data is tied to a device identifier and an account identifier, not to your name or to the content you create.

13.2. Meta SDK. The App includes the Meta (Facebook) software development kit. It reports certain events to Meta so that we can tell which of our marketing campaigns actually bring people to the App: screens viewed, the paywall being shown or dismissed, a purchase being started, completed or failed, decks opened or completed, and cards swiped. Each event carries an anonymous identifier generated by the Meta SDK together with basic device and App information. It does not carry your name, your e-mail address, your answers, your messages or your photos.

13.3. Meta is not merely a supplier acting on our instructions. It uses the information it receives for its own purposes, including measuring and improving advertising, in accordance with its own terms and privacy policy at https://www.facebook.com/privacy/policy. We cannot control or undo what Meta does with it once sent.

13.4. The Meta SDK is configured not to collect the platform advertising identifier directly. On iOS we ask for your permission through Apple’s App Tracking Transparency prompt before allowing this data to be used for advertising purposes. If you decline, we instruct Meta not to use the data for advertising or tracking; the events are still sent, but their use is restricted. You can change your answer at any time in iOS Settings → Privacy & Security → Tracking.

13.5. On Android, the App declares the advertising ID permission. You can delete or reset that identifier at any time in your device settings.

13.6. We do not run advertising inside the App, we do not show you third-party ads, and we do not build profiles about you for anyone else’s advertising.

13.7. Our website may use cookies that are necessary for it to work. You can block them in your browser, though parts of the site may then not function.

14. Changes to this Policy

14.1. We may update this Policy. Each version is published at https://shablon.app/privacy with the date it takes effect, and previous versions remain available at a permanent link.

14.2. If a change materially affects your rights, we will tell you in the App or by e-mail before it takes effect, rather than quietly replacing the page.

15. Language

15.1. The authoritative version of this Policy is the Russian-language version published at https://shablon.app/privacy, because our processing is governed by Russian law. This English version is provided so that our practices are understandable to users who do not read Russian. Where the two differ in meaning, the Russian text governs.

16. How to contact us

We read every message sent to that address, and a person answers it.