1. General Provisions

This Privacy Policy (hereinafter — the "Policy") defines the procedure for processing personal data and the measures taken to ensure the security of personal data by sole proprietor Zavyalov R.V. (hereinafter — the "Operator").

The Policy governs the procedure and conditions of processing personal data of users of the mobile application "Skill" (hereinafter — the "Application"), as well as measures to ensure their protection and confidentiality.

Processing is carried out in accordance with applicable legislation, including Federal Law of the Russian Federation No. 152-FZ "On Personal Data" and the General Data Protection Regulation (GDPR), if applicable.

2. Purposes of Processing

Personal data is processed for the following purposes:

• providing access to the Application functionality and fulfilling obligations to the User;
• improving the quality of the Application, analytics, and debugging errors;
• sending notifications, informational and advertising messages (with the User’s consent);
• complying with legal requirements.

3. Processed Data

When using the Application, the following User data may be processed:

• nickname / username;
• email address;
• password (when registering via e-mail);
• photos (avatar, images uploaded by the User);
• chats and messages;
• social authorization data (Google, Apple ID, VK — email if available);
• gender (if provided);
• date of birth (if provided);
• weight data (if provided);
• User’s movement data (records of route points, including coordinates, speed, time, and other movement parameters);
• User’s geolocation may be available to their friends by User’s choice;
• technical information necessary for analytics and crash reporting (for example, device model, OS and app version, IP address, date and time of use, actions before the crash, and other diagnostic data). These data may be transferred to third parties providing data processing services for analytics and ensuring the stability of the Application.

4. Data Processing

Processing means any action or set of actions, including collection, recording, systematization, storage, updating, use, transfer, depersonalization, blocking, deletion, and destruction of data.

Processing may be carried out both with the use of automation tools and without them.

5. User Rights

The User has the right to:

• receive information about the fact, composition, and purposes of data processing;
• request correction, blocking, or deletion of data;
• withdraw consent to data processing by sending a request to support@skill.ski; withdrawal of consent entails deletion of the account and all related data;
• independently delete the account and related data in the Application (via: Profile → Settings → Account Management → Delete account).

6. Data Storage and Protection

Data is stored no longer than necessary for the purposes of processing or within the time limits established by law.

The Administration applies organizational and technical protection measures appropriate to current risks. However, the User should be aware that no method of storage and transmission of data is absolutely secure.

Access to the data is limited to persons authorized by the Operator to process personal data.

7. Children’s Privacy

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to take necessary actions.

8. Contacts

If you have any questions about this Privacy Policy or the processing of your personal data, please contact us at: support@skill.ski.

9. Final Provisions

The text of this Policy is published in the Application and on the official website in open access.

If significant changes are made to this Policy that affect the purposes, scope, or legal basis of data processing, we will request your renewed consent before such changes take effect.

Version: v1, update date: 21.08.2025