Personal Data Processing Policy
Effective date: 18 September 2026
Version: legal-v1.1.0
This English text is a translation of the Policy governing the processing and protection of personal data in the CREWA mobile application, crewa.ru and related services (the Service). The Russian version controls. This Policy does not replace a separate consent where Russian law requires one.
1. General provisions and Operator
The personal-data operator is Individual Entrepreneur Konstantin Valerievich Inozemtsev, OGRNIP 309774608400270, INN 773165140009. Data-subject requests: support@crewa.ru.
The Policy applies to personal data received through the Service and is implemented under Russian law, including Federal Law No. 152-FZ on Personal Data.
2. Personal data processed
Depending on the functions used, the Operator may process information provided by the User, including name, email, date of birth, gender, profile photograph and other profile information; photographs, comments, posts and other Content; support communications; and data received from a connected service with the User's permission.
The Operator may also process running date and time, route and geolocation, distance, duration, speed, pace, steps and activity metrics; CREWA Marshal purchase and entitlement information; IP address, device and app identifiers, operating system, language, time zone, logs, cookies and similar technical data. Data requiring device, operating-system or third-party permission is processed only after that permission is provided.
3. Processing purposes
The Operator processes data to register and identify Users; provide the Service and CREWA Marshal; record activities and display statistics, rankings and achievements; process payments and perform contracts; provide support; protect the Service and prevent fraud and misuse; analyze and improve operation; develop functions; and comply with Russian law.
4. Recipients
Data may be disclosed only as necessary to operate the Service, perform obligations or comply with law. Recipients may include payment services and app stores; hosting, cloud infrastructure, analytics and support providers; and authorities or other authorized persons where Russian law requires disclosure. The Operator takes reasonable measures to protect confidentiality and security when engaging providers.
User Content and visibility
User Content may contain personal data, including a profile photograph, name, post text and activity information the User chooses to share. The Operator processes this data to store and display material to the relevant audience, operate social functions, address rights complaints and protect the Service. The content licence in the Terms of Use does not replace a separate consent to process or publicly disseminate personal data where law requires it.
The audience depends on the chosen function and visibility settings shown to the User. Before publishing, review which profile details, photographs, activity metrics and route parts will be available to others. Public information may be copied by others. Do not disclose another person's private information without permission. Permission to record geolocation or obtain health information does not by itself authorize public sharing.
Providers are described in section 4, retention and deletion in section 5, and User rights in section 6. The User may use available privacy and deletion controls or contact support@crewa.ru. Content rights and infringement reports are described in section 6 of the Terms of Use.
5. Retention and security
The Operator implements legal, organizational and technical safeguards against unauthorized or accidental access, destruction, modification, blocking, copying or disclosure. Data is processed and stored for the period needed for the relevant purpose unless Russian law requires otherwise. When the purpose is achieved or another legal ground arises, data is deleted or anonymized unless continued retention is legally required. The User must also protect Account credentials and promptly report loss of access or suspected unauthorized use.
6. User rights
Subject to Russian law, the User may request information about processing; correction, blocking or deletion of incomplete, outdated, inaccurate, unlawfully obtained or unnecessary data; withdraw consent where permitted; and delete the Account through available Service functionality or by contacting the Operator.
7. Children and minors
CREWA is not directed to children under 13. A person under 13 may not create an Account or use the Service, even with permission from a parent or legal guardian.
The Operator does not knowingly collect personal data from children under 13. If the Operator learns that a child under 13 provided data or created an Account, it will take reasonable steps to restrict the Account and delete the data and associated Account, subject to appropriate verification, legal or security retention and the controlled backup cycle.
Users aged 13 to 17 may use CREWA subject to applicable law. Where consent is the applicable legal basis for a particular processing activity and law requires authorization by a parent or legal guardian, that authorization must be obtained before processing begins. The Operator may use reasonable and proportionate verification where law permits.
A parent or legal guardian who believes a child under 13 provided personal data may contact support@crewa.ru. The Operator may request information reasonably necessary to identify the Account and verify identity and authority. Do not send passwords, payment details, identity documents or unnecessary sensitive information unless requested through a secure channel.
8. Changes
The Operator may update this Policy. A new version takes effect when published unless it states another date. Continued use is treated as acceptance only to the extent permitted by law; a separate consent will be requested where a new processing activity or purpose requires it.
9. Contact details
Operator: Individual Entrepreneur Konstantin Valerievich Inozemtsev
OGRNIP: 309774608400270
INN: 773165140009
Email: support@crewa.ru
Website: https://crewa.ru