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:
Operator | Individual Entrepreneur Vladislav Ruslanovich Pigin |
Registered in | The Russian Federation |
State registration number (OGRNIP) | 324508100063572, registered on 5 February 2024 |
Taxpayer number (INN) | 505027528954 |
Address | Apt. 76, Bldg. 2, 18 Komarova St., Shchelkovo, Moscow Region, 141100, Russian Federation |
brandmynameis3@mail.ru | |
Telephone | +7 (929) 513-72-16 |
Website | https://shablon.app |
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:
Category | What it includes | Where it comes from |
Account information | Your e-mail address, display name, account identifier; your Apple ID identifier if you use Sign in with Apple | You, when you register |
Profile information (all optional) | Date of birth, gender, partner’s name, living situation, relationship stage, relationship start date, profile photo, an additional e-mail address for anniversary letters | You, if you choose to fill it in |
Content you create | Custom decks and cards, answers to questions, messages and reactions in shared modes, photos and other media, shared timeline events | You, as you use the App |
Device and usage information | Device and installation identifiers, operating system and version, App version, language, IP address, push notification token, dates and times of actions, screens viewed | Collected automatically |
Payment information | Which plan you chose, amounts, dates and statuses of payments, payment identifier, a token representing your saved payment method, the masked card number, card scheme and expiry date, and a card fingerprint | From the payment provider or app store |
Advertising and attribution identifiers | An anonymous identifier generated by the Meta SDK; the advertising identifier provided by your platform where it is available (the Google Advertising ID on Android; on iOS the Apple identifier is used only if you allow tracking) | Collected automatically |
Consent records | Which consents you gave or withdrew, when, from which device, and which version of the document you were shown | Recorded automatically |
Support correspondence | What you write to us and any files you attach | You, when you contact us |
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
Purpose | Information used | Basis |
Creating your account and signing you in | Account information | To perform our contract with you |
Giving you access to the App, storing and syncing your data across devices | Account, profile, content, device information | To perform our contract with you |
Running shared features: pairs, shared decks, online rooms, messaging | Content, account information | To perform our contract with you |
Personalising which questions and cards you see | Profile and usage information | To perform our contract with you |
Taking payment, renewing subscriptions and issuing receipts | Account and payment information | To perform our contract with you |
Bookkeeping and tax records | Account and payment information | To comply with Russian law |
Service messages: upcoming and completed charges, account status, replies to you | Account information, push token | To perform our contract with you |
Preventing abuse of the free trial and keeping the App secure | Device identifier, card fingerprint, IP address | Our legitimate interest in preventing fraud |
Understanding how the App is used so we can improve it | Device and usage information | Our legitimate interest in improving the service |
Proving that you gave or withdrew a consent | Consent records | Our legal obligation to be able to demonstrate consent |
Measuring our marketing and attributing installs and purchases | Advertising and attribution identifiers, in-app events, device information | Your consent, which you can withdraw at any time |
Sending you marketing messages | Account information, push token | Your consent, which you can withdraw at any time |
Defending our rights in a dispute | Whatever is relevant to that dispute | Our legitimate interest in defending legal claims |
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.
Provider | Location | What they do and what they receive |
YooMoney NBCO LLC (YooKassa) | Russian Federation | Processes card payments, stores the payment-method token, issues fiscal receipts. Receives: e-mail address, payment data |
Yandex.Cloud LLC | Russian Federation | Hosts our servers, database and file storage. Technically has access to all data listed in Section 4 |
Yandex LLC (AppMetrica) | Russian Federation | Product analytics. Receives: device and installation identifiers, technical data, in-app actions, purchase events |
RevenueCat, Inc. | 1032 E Brandon Blvd #3003, Brandon, FL 33511, USA | Manages subscriptions bought through app stores. Receives: account and device identifiers, subscription and purchase data |
Apple Inc. / Apple Distribution International Ltd. | Cork, Ireland and Cupertino, USA | Sign in with Apple, App Store payments, push notification delivery |
Google LLC / Google Ireland Limited | Dublin, Ireland and Mountain View, USA | Google Play payments, push notification delivery |
Meta Platforms, Inc. / Meta Platforms Ireland Ltd. | 1 Hacker Way, Menlo Park, CA 94025, USA; 4 Grand Canal Square, Dublin 2, Ireland | Measures our marketing and attributes installs and purchases. Receives: in-app events (screen views, paywall shown or dismissed, purchase started, completed or failed, decks opened or completed, cards swiped), an anonymous Meta identifier, device and App data. Meta is an independent company and uses this information for its own purposes under its own terms — see Section 13 |
650 Industries, Inc. (Expo) | 624 University Ave FL1, Palo Alto, CA 94301, USA | Delivers push notifications. Receives: push token, device identifier, the text of the notification |
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
Information | Kept for |
Account, profile and content | For as long as your account exists |
Content in shared modes | Until you delete it, or until your account is deleted |
Payment records and accounting documents | 5 years from the date of the payment, as required by Russian tax and accounting law |
Consent records | 3 years after processing ends, so we can show what you agreed to |
Anti-abuse records (device identifier, card fingerprint) | 3 years, including after account deletion — see clause 8.2 |
Analytics data | 2 years |
Support correspondence | 3 years from your last message |
Anything relevant to a dispute | Until the dispute is resolved and the limitation period expires (normally 3 years) |
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
brandmynameis3@mail.ru | |
Telephone | +7 (929) 513-72-16 |
Postal address | Apt. 76, Bldg. 2, 18 Komarova St., Shchelkovo, Moscow Region, 141100, Russian Federation |
Support hours | Daily, 11:00–15:00 Moscow time (UTC+3) |
Responsible person | Individual Entrepreneur Vladislav Ruslanovich Pigin |
We read every message sent to that address, and a person answers it.