Spectrum of Soul

Effective Date: February 5, 2026

1. General Provisions

This Privacy Policy (hereinafter referred to as the “Policy”) describes the procedures for the collection, storage, use, and disclosure of information about users of the Spectrum of Soul digital services, including the mobile application, the official website, and related online services (collectively, the “Services”).

The data controller is Individual Entrepreneur AI Kefalidi, registered in accordance with the laws of Georgia, identification number: 347007534, registered address: Georgia, Kobuleti region, village Tsikhisdziri (hereinafter referred to as “we,” “us,” or the “Company”).

We respect your privacy and are committed to protecting personal data in accordance with applicable laws of Georgia, as well as generally accepted international data protection standards.

By using the Services, you confirm that you have read this Policy and agree to its terms.

2. Scope

This Policy applies to all information that we collect:

• when using the Spectrum of Soul mobile application;
• when visiting and using the official website https://spectrumofsoul.ru;
• when using the digital goods and services store available on the website;
• when interacting with the functionality of the Services, including in-game features;
• when contacting customer support.

This Policy does not apply to third-party websites, services, or applications that may be accessed via links from the Services.

3. Information We Collect

We may collect the following categories of data:

3.1. Personal Data

Information that can be used to identify a user, including:

• email address;
• username (nickname);
• account identifier;
• data provided when contacting customer support;
• other data voluntarily provided by the user when using the Services.

3.2. Non-Personal Data

Information that does not directly identify a user, including:

• device type, model, and operating system;
• unique device identifiers;
• IP address;
• interface language;
• data on the use of the Services (progress, choices within stories, in-game actions);
• technical logs, error data, and crash reports.

4. How We Use Your Information

Collected information is used for:

• providing and maintaining the proper operation of the Services;  
• saving user and gameplay progress;  
• personalizing the user experience;  
• improving content, mechanics, and overall service quality;  
• handling customer support requests;  
• sending service-related notifications about updates and changes;  
• ensuring security and preventing abuse.

The processing of personal data is carried out on the following legal grounds:

• the user’s consent;
• the necessity to perform contractual obligations related to the provision of the Services;
• the legitimate interests of the Company aimed at improving the quality and security of the Services, provided that such interests do not override the user’s rights.

We may use the user’s email address to send informational and service-related communications related to the operation of the Services, including notifications about updates, new features, content, in-game events, promotions, and special offers of the Spectrum of Soul project.

The user has the right to opt out of receiving such communications at any time by following the unsubscribe link included in each email or by sending a corresponding request to the Company using the contact details provided in this Policy.

We may use automated data processing tools, including analytics tools, to analyze the operation of the Services and improve the user experience.
Such processing is not intended to result in decisions that produce legal effects for the user.

We do not use personal data for purposes incompatible with those described above.

5. Sharing of Information with Third Parties

We do not sell users’ personal data and do not share it with third parties, except in the following cases:

• engagement of technical service providers (analytics, hosting, payment processing);
• compliance with applicable laws or lawful requests from public authorities;
• protection of the rights and legitimate interests of the Company and users.

All third-party partners are required to ensure an adequate level of protection of personal data.

In the course of using the Services, personal data may be processed and stored on servers located outside of Georgia, including in countries where the Company’s technical service providers are located.

In such cases, the Company takes reasonable measures to ensure an adequate level of protection of personal data in accordance with applicable laws.

6. Payments and Purchases

Purchases of digital goods and services may be made through third-party payment platforms, including but not limited to Google Play, the App Store, as well as payment services used on the official website of the project.

We do not store or process users’ bank card details. Payment information is processed and governed by the policies of the respective payment providers.

7. Cookies and Tracking Technologies

We may use cookies and similar technologies (such as SDKs and device identifiers) for the following purposes:

• analyzing the operation of the Services;
• improving stability and performance;
• collecting anonymous statistical data.

Browser cookies are used when accessing the web versions of the Services, where necessary for their proper functioning.

8. User Rights

The user has the right to:

• request access to their personal data;
• request correction or deletion of their data;
• withdraw consent to the processing of personal data;
• lodge a complaint with the relevant data protection authorities.

Requests may be submitted using the contact details provided below.

9. Account Deletion

Users can delete their account at any time directly within the Services by using the “Delete Account” option available in the application settings.

Alternatively, users may request account deletion by contacting us at: spectrumofsoulll@gmail.com with the subject line “Account Deletion”.

Upon deletion, the user’s account and associated personal data will be removed within a reasonable timeframe, unless retention is required by applicable law.

10. Data Retention

Users’ personal data is retained no longer than necessary for the purposes set out in this Policy, or until the user withdraws their consent, unless otherwise required by applicable law.

11. Data Security

We implement reasonable technical and organizational measures to protect information from:

• unauthorized access;
• loss;
• alteration;
• disclosure.

However, no method of data transmission over the Internet can be guaranteed to be completely secure.

12. Children’s Privacy

The Services are not intended for individuals under the age of 16.

We do not knowingly collect personal data from such users. If you become aware that a child has provided us with personal data without parental or legal guardian consent, please contact us.

13. Changes to This Policy

We may update this Policy from time to time.

The current version is always available within the Services or on the official website of the project. Continued use of the Services constitutes acceptance of the updated version of the Policy.

14. Governing Law and Jurisdiction

This Policy shall be governed by and construed in accordance with the laws of Georgia.

Any disputes arising out of or in connection with this Policy or the use of the Services shall be resolved in accordance with applicable law in the competent courts of Georgia, unless otherwise required by mandatory provisions of applicable law.

15. Contact Information

For any questions related to privacy and the processing of personal data, you may contact us at:

Email: spectrumofsoulll@gmail.com
Subject line: Privacy / Personal Data