Privacy Policy — NDK Games

Last updated: 08 December 2025

1. General Provisions

1.1. This Privacy Policy (the “Policy”) explains how NDK Games (“Company”, “we”, “us”, “our”) collects, uses, stores, and protects personal data and other information obtained from users of our products and services.

1.2. For the purposes of this Policy, “Products and Services of the Company” include, without limitation:

Mobile applications (e.g., for Android, iOS and other platforms);
Websites and web applications;
Chatbots and mini-apps (for example, in Telegram or other messengers);
APIs and other online services operated by the Company.

1.3. By using any of our Products or Services, you acknowledge that you have read this Policy, understand it, and agree to be bound by it. If you do not agree with this Policy, you must stop using our Products and Services.

1.4. Our Products and Services are intended for users aged 18 and older. By using our Products and Services, you confirm that you are at least 18 years old and have the legal capacity to enter into binding agreements.

1.5. We process your personal data in accordance with applicable data protection laws, which may include, where applicable, the EU General Data Protection Regulation (GDPR) and relevant national data protection legislation.

2. Data Controller and Contact Details

2.1. The data controller responsible for processing your personal data is:

NDK Games
(Full legal details may be provided in a separate Terms of Use, Imprint, or on the Company’s website.)

2.2. For any questions, comments or requests regarding this Policy or the processing of your personal data, you may contact us at:

Email: support@ndkgames.com

3. Scope of the Policy and Relationship with Third-Party Policies

3.1. This Policy applies to information that we obtain when you:

Use our mobile applications;
Visit and use our websites and web services;
Interact with our chatbots and mini-apps (in messengers and other platforms);
Use our APIs and other online services;
Contact us via support or other communication channels.

3.2. The processing of your data by third-party platforms (for example, Telegram, Google Play, Apple App Store, payment providers, advertising networks, analytics platforms, etc.) is governed by their own privacy policies and terms of use. We do not control such processing and are not responsible for it.

3.3. For specific Products or Services, additional or more detailed terms or separate privacy policies may apply. In case of any conflict between this Policy and a more specific privacy document applicable to a particular product, the more specific document will prevail for that product.

4. Categories of Data We May Process

The scope of data we process depends on which of our Products and Services you use and which features are enabled.

4.1. Identification and Contact Data

We may process:

Account identifiers on third-party platforms:
- Telegram ID, username, display name (for bots in messengers);
- Account identifiers within our own systems (if you register an account directly with us);
Contact details you provide:
- Email address;
- Name, nickname or other profile details;
- Phone number or other contact data, where applicable;
Other identifiers:
- Device and installation identifiers (e.g., app instance ID, analytics SDK identifiers, Firebase Instance ID, etc.);
- Advertising identifiers (e.g., Google Advertising ID, IDFA/IDFV on iOS), if permitted by platform rules and your device settings.

4.2. Profile Data and Settings

Language and regional preferences;
User role within our systems (e.g., standard user, administrator);
Saved preferences and configuration in our Products and Services (themes, model parameters, preferred response format, etc.);
Referral-related data (your referral code, who referred you, and whom you referred).

4.3. Content You Provide and Interaction Data

Text messages, comments, prompts, and other content you submit;
Commands and structured inputs you send via our apps, bots, or APIs;
Files and other materials you upload (within supported formats), including but not limited to:
- Documents, text files, presentations, spreadsheets;
- Images and graphics;
- Audio and video files;
- Archives, project files, source code and other data;
Results of processing such files (for example, extracted text, summaries, structured data);
Responses and content generated by our systems and/or models based on your inputs, to the extent we store them for history, analytics or re-use.

4.4. Payment and Billing Data

Information about your internal balance or credits within our Products and Services (if such a system exists);
Transaction history: top-ups, deductions, earned or granted bonuses, referral rewards;
Payment transaction details: amount, currency, date and time, transaction ID from the payment provider, transaction status;
Data necessary for accounting and tax reporting.

We do not store full bank card details or other sensitive payment data processed directly by payment providers (banks, payment gateways, app stores, etc.).

4.5. Technical and Analytics Data

Date and time of access to our Products and Services;
Device type, model, operating system version;
Application version or client version;
IP address, country/region derived from IP (where applicable);
Browser type and version (for web);
Technical logs: error codes, response codes, internal request identifiers;
Performance metrics: processing times, resource usage;
Analytics and diagnostics events (crash reports, feature usage statistics, etc.);
Information related to cookies or similar technologies (for web and, where applicable, mobile SDKs).

4.6. Cookies and Similar Technologies

When you use our websites and web applications, we may use:

Cookies;
Local storage / session storage;
Pixels, tags, and similar tracking technologies.

These may be used for:

Authentication and session management;
Saving user preferences;
Analyzing traffic and usage patterns;
Personalizing content and/or advertising (where allowed and applicable).

Additional details may be provided in a separate Cookie Policy or cookie banner.

4.7. Special Categories of Data

We do not intentionally seek to collect special categories of personal data (such as data about health, religious beliefs, political opinions, etc.). If you voluntarily include such information in your requests, files, or messages, you acknowledge that it may be processed technically as part of the general functionality of our Products and Services.

5. Sources of Data

We may obtain data:

Directly from you (when you register, use our apps, send messages, upload files, contact support, etc.);
From platforms and partners (messengers, app stores, payment providers, analytics and diagnostic tools);
From publicly available sources, if you have made your information public;
Automatically via technical means (cookies, SDKs, log files, etc.).

6. Purposes of Processing Personal Data

We process your data for the following purposes:

6.1. Providing Our Products and Services

Operating and maintaining our apps, websites, bots, APIs and related infrastructure;
Processing your requests and messages and providing responses and functionality;
Handling files you upload: receiving, storing, processing them and delivering results;
Generating content (text, images, video, audio, etc.) using our technologies and models;
Maintaining an interaction history to the extent necessary for functionality (context, re-use of content, “retry” features, etc.).

6.2. Account and Access Management

Registering and authenticating users (where applicable);
Assigning roles and permissions (e.g., user, administrator);
Maintaining your settings and personalization.

6.3. Billing and Payments

Calculating the cost of using paid features;
Tracking and adjusting balances, credits, or other internal units;
Processing payments and top-ups via payment providers;
Complying with accounting and tax obligations.

6.4. Analytics, Improvement and Development

Analyzing usage statistics for features, models, tariffs and plans;
Improving performance, reliability and user experience;
Testing new features and refining existing functionalities.

6.5. Security and Abuse Prevention

Detecting, preventing and responding to fraud, hacking, spam and other forms of abuse;
Protecting the rights and legitimate interests of the Company, users and third parties;
Managing blocks, restrictions and “blacklists” for users who violate terms of use.

6.6. Legal Compliance

Fulfilling legal obligations (including tax and accounting requirements, data retention rules and others);
Responding to lawful requests from public authorities and courts.

6.7. Communications

Sending service messages (e.g., information about changes to terms, critical updates, account-related notices, technical incidents);
Sending informational and marketing communications, where permitted by law and where you have not objected or have given consent where required.

7. Legal Bases for Processing

Depending on the context, we rely on the following legal bases for processing your personal data:

Performance of a contract or taking steps at your request prior to entering into a contract
To provide you with access to and use of our Products and Services.
Legitimate interests of the Company
For example, for analytics, fraud prevention, improving our services, maintaining security, provided that such interests are not overridden by your rights and freedoms.
Compliance with legal obligations
When we are required to process data by law (e.g., tax, accounting, reporting obligations).
Consent
When processing cannot be based on other legal grounds (e.g., certain types of marketing communications or specific cases where consent is required by law).

8. Disclosure and Sharing of Data with Third Parties

We may share your data with the following categories of recipients:

8.1. Infrastructure and Hosting Providers

Providers of servers, databases, cloud storage and other infrastructure;
Providers of object storage (e.g., S3-compatible storage);
Logging and monitoring services.

8.2. Analytics and Diagnostic Providers

Web analytics tools;
Mobile analytics SDKs;
Crash reporting and diagnostics services.

8.3. Payment Providers

Banks, payment gateways, in-app payment services, digital token / in-app currency providers;
Data is shared to the extent necessary to process payments, issue refunds and comply with financial and legal requirements.

8.4. Technology and AI Service Providers

Providers of AI models and computational infrastructure for processing requests, generating content, speech recognition and similar tasks;
In such cases, the data shared is limited to what is necessary to perform the specific operation.

8.5. Professional Advisors and Other Contractors

Legal, financial and other professional advisors, auditors and similar parties, where data is necessary for them to provide services to us and they are bound by confidentiality obligations.

8.6. Public Authorities and Other Third Parties

Where disclosure is required by law or binding order;
Where it is necessary to protect our rights, the rights of users, or of third parties.

We do not sell your personal data to third parties.

9. International Data Transfers

9.1. Our servers and the servers of our contractors and partners may be located in different countries, including countries outside your country of residence and outside the European Economic Area (EEA).

9.2. Where personal data is transferred to countries without an adequate level of data protection, we take appropriate safeguards as required by law (for example, using Standard Contractual Clauses or other legally recognized transfer mechanisms).

10. Data Retention

10.1. We retain personal data only for as long as necessary to achieve the purposes set out in this Policy or for the period required by applicable law.

10.2. In general, and subject to legal requirements:

Account and profile data: retained while your account is active and for a reasonable period afterward, if necessary for legitimate purposes (e.g., resolving disputes, enforcing agreements);
Interaction history and content (requests, responses, files): retained for a reasonable period necessary to support functionality, analytics and service improvement;
Technical logs: typically retained for a few weeks or months;
Payment and accounting data: retained for the periods required by tax and accounting laws;
Blocklist / restriction data: retained for the duration of the restriction and for a reasonable time afterward, where necessary to prevent repeated violations.

10.3. When data is no longer needed, it is deleted or irreversibly anonymized.

11. Your Rights

Depending on your jurisdiction and applicable law, you may have the following rights regarding your personal data:

Right of access: to obtain confirmation about whether we process your personal data and, if so, access to that data;
Right to rectification: to have inaccurate or incomplete data corrected;
Right to erasure (“right to be forgotten”): to request deletion of your data, where applicable and not in conflict with legal obligations;
Right to restriction of processing: to request that we limit the processing of your data in certain cases;
Right to object: to object to processing based on our legitimate interests;
Right to data portability: to receive your personal data in a structured, commonly used and machine-readable format and to transmit this data to another controller, where applicable;
Right to withdraw consent: where processing is based on consent, you may withdraw such consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise your rights, you may contact us at support@ndkgames.com. We may request additional information to verify your identity and to clarify your request.

We will respond within a reasonable time and within any deadlines required by applicable law.

12. Children

12.1. Our Products and Services are not directed to children under the age of 18.

12.2. We do not knowingly collect personal data from children. If you believe that a child has provided us with personal data, please contact us at support@ndkgames.com, and we will take appropriate steps to delete such data.

13. Data Security

13.1. We implement technical and organizational measures to protect personal data from unauthorized access, alteration, disclosure or destruction, including:

Restricting access to data to authorized personnel only;
Using secure communication protocols where appropriate;
Storing sensitive secrets and keys securely;
Minimizing the amount of sensitive data included in logs;
Maintaining backups and, where necessary, restoring data;
Monitoring for security incidents and anomalies.

13.2. Despite our efforts, no method of transmission over the Internet or method of electronic storage is completely secure. You are also responsible for maintaining the confidentiality of any credentials used to access our Products and Services and for using our services in a secure manner.

14. Platform-Specific Notes

14.1. Mobile Applications (Android, iOS)

We comply with the privacy and data protection requirements of the relevant app stores (such as Google Play and Apple App Store). Additional information may be displayed in the respective store sections (e.g., “App Privacy”, “Data Safety”).

14.2. Websites and Web Applications

When using our websites and web applications, cookies and similar technologies may be used. Details about the categories of cookies and your choices may be provided in a separate Cookie Policy or via a cookie consent banner.

14.3. Chatbots and Mini-Apps

When using our chatbots and mini-apps (for example, in Telegram or other messengers):

We receive only the data that the platform makes available via its API and that you voluntarily provide to the bot;
The platform (e.g., Telegram) remains an independent data controller for the data it processes directly;
You should also review the platform’s own privacy policy and terms of service.

15. Changes to This Policy

15.1. We may update this Policy from time to time to reflect changes in our activities, Products and Services, or in applicable law.

15.2. The updated Policy will be effective from the date indicated as “Last updated” or from another date specified in the Policy. We may provide additional notice of material changes where required (for example, via our services or by email).

15.3. Your continued use of our Products and Services after the effective date of an updated Policy constitutes your acceptance of the updated Policy.

16. Contact Information

If you have any questions, comments, or requests relating to this Policy or to our processing of personal data, you can contact us at:

Email: support@ndkgames.com