Privacy Policy

Effective date: 25 October 2026.

1. Operator

Operator: Individual Entrepreneur Aleksandr Stanislavovich Kolmachikhin, INN 540549978493, OGRNIP 326547600161892, Novosibirsk, Russia.

Data contact: epic-to-do-list@mail.ru.

App: Epic to-do list, application ID kolmachikhin.alexander.epicto_dolist.

2. Scope and version

This Policy applies to all users. The Operator processes data in accordance with applicable law. If applicable law grants you additional rights, those rights apply alongside this Policy. Nothing in this Policy limits any rights that cannot be limited under applicable law.

This Policy does not apply to third-party websites or services.

3. Data the Operator processes

The Operator does not intentionally collect special categories of personal data, and does not intentionally send task content to Yandex. The App may store whatever you enter in local tasks on your device; please do not enter sensitive data unless you are comfortable storing it locally. The Operator does not request access to your device's precise location, contacts, camera or microphone; the ad SDK may infer an approximate location from your IP address. The Android advertising ID may be used for personalized ads with your consent; Yandex may also process device and ad-interaction data for ad delivery, measurement and fraud prevention under its own policy. Android Auto Backup and device-to-device transfer are disabled; app data is excluded from backup.

4. Purposes and legal bases for processing

Consent can be withdrawn; withdrawal does not affect prior processing. If the Operator relies on legitimate interest, you have the right to object to that processing.

5. Recipients of data

5.1. Yandex AppMetrica. For users in Russia, AppMetrica is provided by Yandex LLC, 16 Lva Tolstogo St., Moscow 119021, Russia. For users in the EEA/UK, it is provided by Air Smart Advertising Solutions FZ-LLC, Dubai, UAE. In both cases Yandex acts as a processor: for the EEA/UK under the AppMetrica data processing agreement (DPA), which includes the EU Standard Contractual Clauses; for Russia under the AppMetrica terms. The App initializes AppMetrica at startup with data sending disabled. No data is sent to Yandex until you enable the analytics option. The SDK may keep technical data in a local buffer; if you enable analytics later, buffered data may be sent. The Operator passes your analytics choice to Yandex Ads; ad analytics reporting is controlled by that choice. Data: sessions and automatic technical events, device/OS/version, IP, pseudonymous ID, install source if available, crashes/ANR. The Operator's AppMetrica configuration disables location tracking and advertising-identifier tracking in AppMetrica. The Yandex Ads SDK may use the advertising ID for ads as described in section 5.2. The Operator intentionally does not send task titles/descriptions, names or email addresses. Crash reports may contain technical context such as the stack trace, device, OS and app version. Withdrawal of analytics stops further sending while the option is off. For details, see the AppMetrica DPA and AppMetrica Terms.

5.2. Yandex Mobile Ads. For users in Russia, the ad service is provided by Yandex LLC, 16 Lva Tolstogo St., Moscow 119021, Russia. For users in the EEA/UK, it is provided by Air Smart Advertising Solutions FZ-LLC, Dubai, UAE; depending on the relationship, another group entity, including Direct Cursus Technology L.L.C., Dubai, UAE, may act as controller. For other regions, the entity named in the applicable Yandex terms applies. Rewarded ads are personalized only with separate consent; otherwise they are non-personalized. An ad is shown only after you choose to watch it. The Android advertising ID may be used for personalized ads with your consent. The Operator does not request access to your device's precise location; the ad SDK may infer an approximate location from your IP address. Opting out of analytics does not disable ads; without consent to personalization, new ad requests are non-personalized. For ads, Yandex acts as an independent controller and processes ad data under its own terms and the Yandex International Ads Privacy Policy, including for ad delivery, measurement and fraud prevention. For details, see the Yandex International Ads Privacy Policy.

5.3. Email provider. Support correspondence is processed by VK LLC (Mail.ru), Moscow, Russia, which acts as the Operator's email provider. The provider processes the email address, message and standard email metadata needed to deliver and store the correspondence. For EEA/UK users, this is a transfer to Russia; information about the applicable safeguards can be requested from the Operator.

5.4. Third parties. The Operator does not control the policies of Yandex or other external services. Their processing is governed by their own documents: Yandex Privacy Policy, AppMetrica Terms, AppMetrica DPA, Yandex Mobile Ads SDK License, YAN DPA, Yandex International Ads Privacy Policy, and VK/Mail.ru Privacy Policy. Yandex may use subprocessors. The Operator may disclose data where required by law.

6. International transfers

Yandex states that data of users in Russia is stored in Russia. For the EEA/UK, the AppMetrica DPA with Air Smart Advertising Solutions FZ-LLC includes the EU Standard Contractual Clauses. Yandex's Privacy Policy also states that data of EEA users may be transferred to Russia and that Yandex relies on Standard Contractual Clauses for that transfer. The Operator relies on those mechanisms. For users in Russia, the Operator processes data in accordance with 152-FZ.

The Operator discloses ad data to Yandex Ads as an independent controller. Yandex Ads may transfer that data to third countries, including Russia and the UAE, as described in the Yandex International Ads Privacy Policy. Yandex Ads is responsible for its own onward transfers; its policy describes the safeguards and provides more information on the transfer mechanisms on request. The Operator will provide information about the applicable safeguard for its disclosure to Yandex Ads on request. For EEA/UK users, support correspondence is transferred to Russia as described in section 5.3; information about the applicable safeguard can be requested from the Operator.

Local tasks are not transferred off the device through backup or operator servers.

7. Retention and deletion

How to delete data. You can remove app content using the in-app data removal option, or delete all local data by clearing app data or uninstalling the App. Support correspondence can be deleted on request at epic-to-do-list@mail.ru. For analytics and crash reports, disable analytics in Settings or uninstall the App to stop further sending while the option is off. For analytics and crash data that has already been transferred, the Operator can forward your request to Yandex, but because the data is pseudonymized, specific records may not be identifiable; some data may remain at Yandex until retention periods expire.

8. Security

The Operator uses technical and organizational measures to protect data, including encryption in transit and limited access. The Operator applies reasonable security measures and will notify regulators and users where required by law. The Operator does not request access to precise device location, contacts, camera or microphone; the ad SDK may infer an approximate location from your IP address, as described in section 5.2. The Operator does not carry out automated decision-making with legal effects.

9. Your rights and complaints

The rights available to you depend on your location and may include access, rectification, erasure, restriction, objection, portability, withdrawal of consent and complaint. These rights apply only to data the Operator can identify. Contact: epic-to-do-list@mail.ru. The Operator verifies requests and responds within the period required by applicable law. If the Operator needs more time, the Operator will tell you. The JSON export includes the main app data: tasks, hero, settings, progress, products and notifications. It may also include technical state needed to restore the App. The consent record is stored locally on your device and is not included in the export. You can view and change your current choices in Settings. Analytics requests are handled on request.

What this means in practice. The rights apply to your personal data. You control local data yourself. If data is pseudonymized and the Operator lacks information to locate it, the Operator may ask for additional details; if a record cannot be identified, the Operator will explain the available options. See “Retention and deletion” above.

How to complain. If you believe the Operator has violated your rights, contact the Operator using the details above. The Operator will review the request and respond. You also have the right to lodge a complaint with a competent supervisory authority.

Analytics sending is off by default and is enabled only with your consent. No analytics data is sent to Yandex until you consent; the SDK may buffer technical data locally as described in section 5.1. You can give, refuse or withdraw consent in the App; your current choice is shown in Settings. The analytics consent covers both analytics and crash reporting. Withdrawing analytics stops further sending of analytics and crash data while the option is off.

Personalized ads. Personalized ads are off by default and are enabled only with separate consent. Without consent, ads are non-personalized. You can change your choice in Settings; after withdrawal, new ad requests are non-personalized.

11. Children

The App is intended for a general audience. It is not designed or marketed for children, and the Operator does not knowingly collect personal data from children. If you are below the age at which you can consent to data processing in your country (for example, under 16 in some EEA countries), use the App only with parent or guardian consent. If you believe a child has provided personal data, contact the Operator.