时钟应用隐私政策

Effective date: 10 October 2026

This Privacy Policy (the “Policy”) describes what data is processed when you use the Android mobile application “Wall Clock” (the “App”), for what purposes it is processed, who it may be shared with, and what rights you have.

By using the App, you confirm that you have read this Policy. If you do not agree to the data processing terms, you should stop using the App and delete it from your device.

1. Controller and contact details

The controller in respect of data processed by the App developer is individual entrepreneur Khakimov Rinat Rimovich (the “Developer”).

• Email: Rino2020@mail.ru

For questions about personal data processing, withdrawing consent, or clarifying, blocking or deleting data, you may contact the email address above.

The Yandex advertising network, as well as VK Ads / myTarget and MyTracker (VK LLC), with respect to data that their software (SDKs) collect on their own, act as independent controllers of such data. Their processing rules are set out in their own privacy policies (links are provided in section 5).

2. Data the App does not collect on its own

The App does not require registration, does not create a user account, and does not itself request or send the following data to the Developer:

• full name;
• email address;
• phone number;
• payment details and bank card information;
• exact residential address;
• photos, contacts, messages and user files.

To display the time, the App may use local device information (system time, time zone, regional settings). This information is processed on the user’s device and is not sent to the Developer as a separate personal data database.

3. Why data is processed in the App

The App is free and contains advertising. In addition to the Yandex advertising network, the App includes software (SDK) of the VK Ads / myTarget advertising network. Together with myTarget, the App also includes the MyTracker analytics and attribution SDK. Both products belong to VK LLC, not to Yandex and not to Google. They are connected through Yandex Mobile Ads mediation: when Yandex selects an ad, the impression may be served through VK Ads / myTarget.

The Developer does not send these SDKs a name, email address, phone number, payment details or precise coordinates. The App does not request location permission. The data that the SDKs may obtain from the device is determined by the documentation and policies of VK LLC and may depend on the SDK version, device settings, Android permissions and whether ad personalization is enabled.

4. Data collected by advertising networks

The categories below may, according to the official documentation of the advertising networks, be collected and transmitted when ads are shown in a mobile app. The Developer does not receive from the advertising networks a database of such data that would allow the Developer to identify a specific user on its own, and does not sell personal data.

4.1. Yandex advertising network

According to the Yandex advertising services privacy policy and the Yandex Mobile Ads SDK documentation, the following may be processed when ads are shown in publishers’ apps, in particular:

• device IP address;
• advertising device identifier (GAID / AAID for Android) and other device identifiers — if the relevant permission is granted and the user has not restricted their use in system settings;
• device information and parameters (including model and other technical characteristics);
• Android operating system version;
• type of internet connection;
• SIM card data limited to country and operator network codes (MCC / MNC);
• cookies and similar technical identifiers — where ad content uses web technologies;
• identifiers of third-party advertising systems (if available to the SDK);
• other data that the publisher or the device transmits to the SDK in connection with showing ads.

Yandex Mobile Ads SDK does not collect precise or approximate geolocation by default. Coordinates may be transmitted only if the Developer has specifically enabled such transmission and the user has granted the app location permission. In the current App configuration, the Developer does not intentionally send coordinates to the Yandex SDK.

Yandex states that the listed data types for personalized advertising are optional: the user may limit ad personalization in Android settings. Data in transit is protected by the HTTPS/TLS protocol.

Yandex’s processing purposes include showing ads (including personalized ads where consent has been given), showing non-personalized ads, fraud prevention, security and compliance with the law.

4.2. VK Ads / myTarget

According to the myTarget (VK LLC) privacy policy, the following may be processed when ads are shown in partners’ apps, in particular:

• the device advertising identifier (GAID / AAID for Android) and other technical identifiers of the mobile device;
• IP address;
• device and operating system information (model, OS version, language, screen resolution and other technical parameters);
• information about the app in which the ad is shown;
• network and internet service provider information;
• statistics of interactions with ads (impressions, clicks and other advertising-related events).

Purposes of processing: showing ads (including personalized ads if this is allowed by the device settings), measuring performance, fraud prevention and operation of the advertising network.

myTarget policy: https://target.vk.ru/help/advertisers/privacy_policy/

4.3. MyTracker

MyTracker is an analytics and attribution SDK of VK LLC. It is included in the App as part of the VK Ads / myTarget stack, not as a separate service of the Developer.

According to the MyTracker privacy policy, when the SDK runs the following may be processed, in particular:

• technical device information (type and model, OS version, system language, screen resolution, mobile carrier, internet service provider, date and time of access to the app, and similar parameters);
• technical identifiers (an IP address that may give a general idea of the region; User-Agent; Google / GAID advertising identifier; Android ID and similar identifiers);
• information about app use and interaction with ads (launches, ad impressions and clicks, and other events needed for measurement and attribution).

The Developer does not send MyTracker its own user identifier, an email address or a phone number.

Purposes of processing: analytics, attribution of installs and advertising campaigns, measuring ad performance, fraud prevention and operation of VK LLC services.

MyTracker policy: https://tracker.my.com/ru/legal/privacy-policy

The independent controller of the data collected by myTarget and MyTracker is VK LLC. The Developer does not sell users’ personal data.

5. Sharing data with third parties

The data described in section 4 is transmitted directly to advertising networks through the embedded SDKs. The Developer does not sell users’ personal data.

Independent controllers (recipients) of the data:

• Yandex — privacy policy: https://yandex.ru/legal/confidential/; advertising services policy: https://yandex.com/legal/international_ads_privacy_policy/;
• VK Ads / myTarget — privacy policy: https://target.vk.ru/help/advertisers/privacy_policy/
• MyTracker — privacy policy: https://tracker.my.com/ru/legal/privacy-policy

Advertising networks may engage their partners, affiliates and contractors (including for showing ads, measurement and fraud prevention) in accordance with their policies. Data may be processed on servers located in the Russian Federation and in other countries. Transfers outside the Russian Federation are carried out by the advertising networks under the terms of their documents and applicable law.

The Developer may disclose data in its possession to public authorities in cases expressly provided for by the law of the Russian Federation.

6. Legal bases for processing

Data is processed in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other applicable rules, as well as app store rules and the advertising networks’ policies.

Legal bases may include:

• the user’s consent to personal data processing and to personalized advertising — if such consent has been requested and given (including through Android system settings or a consent dialog in the App);
• processing necessary for the App to function and to show advertising as the way the App is provided free of charge;
• compliance with legal requirements, fraud prevention and security.

Refusing personalized advertising generally does not mean there will be no ads at all: the user may still be shown non-personalized ads.

7. Retention period

The Developer does not keep its own database of the App users’ advertising identifiers. The retention period for data collected by advertising networks is determined by their privacy policies and is needed for showing ads, measurement, fraud prevention and legal compliance.

Local App settings are stored on the user’s device until the App is deleted or until the app data is cleared in Android settings.

8. User rights

The user has the right to:

• obtain information about the processing of their personal data;
• request that data be corrected, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or is not necessary for the stated processing purpose;
• withdraw consent to personal data processing if processing is based on consent;
• appeal the controller’s acts or omissions to the authorized personal data protection authority (Roskomnadzor) or to a court.

To exercise rights in respect of data held by the Developer, send a request to Rino2020@mail.ru. In the request, state that it concerns the “Wall Clock” app, the substance of the request and a way to contact you. The Developer will consider the request within the time limits provided by law.

For data collected by Yandex, myTarget or MyTracker on their own, the user may also contact the relevant controller using the contacts in its privacy policy. The independent controller of myTarget and MyTracker data is VK LLC.

9. How to limit advertising data collection on the device

An Android user may:

• in Google settings (Privacy / Ads) reset the advertising identifier or turn off ad personalization;
• withdraw previously given consent to personalized advertising if such a prompt is shown in the App;
• delete the App from the device — after that the App stops sending new data, but data already received by advertising networks is stored and deleted under their rules.

10. Children

The App is not intended for children, is not directed at an audience under 16 and does not knowingly collect children’s personal data. If a legal guardian believes that a child provided data through the App’s advertising services, they should write to Rino2020@mail.ru. The Developer will take reasonable steps, including contacting advertising partners if necessary.

11. Security

The Developer takes reasonable organizational and technical measures to protect information in its possession. Data transmission by advertising SDKs is carried out over protected connections (HTTPS/TLS) as implemented by the relevant networks. Absolute security of data transmission over the Internet cannot be guaranteed.

12. Changes to the Policy

The Developer may change this Policy. The current version is published on this page. Continued use of the App after a new version is published means agreement with the updated terms to the extent permitted by law. Where possible, the Developer reflects material changes in the date at the beginning of the document.

13. Final provisions

This Policy was prepared with regard to the official Yandex Mobile Ads SDK documentation and the myTarget and MyTracker (VK LLC) privacy policies in effect on the publication date. If an advertising network’s or service’s documentation changes, the data actually collected may be clarified in the Yandex and VK LLC policies linked in section 5.

The privacy policy of the website where this document is published is provided separately: 隐私政策.