legal

Privacy Policy

Revision of 28 September 2026. Effective from the date of publication on this page. The Russian and English versions are equally authentic; for users in Russia the Russian version prevails in case of divergence.

1. Controller

The controller of personal data (the operator under Russian law) is Dmitrii Bazhin, owner of the service and of papanumbers.com. The EU representative (Art. 27 GDPR) is Maksym Samokhin (the Netherlands). Contact for data matters: legal@papanumbers.com; we reply within one month.

2. What data we process

  • E-mail address — account, sign-in, e-mails.
  • Birth date — the number is computed from it (Section 3).
  • Country — for country breakdowns of answers.
  • Public name — optional.
  • Time-capsule content — text, sometimes photos (Section 6).
  • Chat messages, comments and reactions (Section 7).
  • Telegram identifier (chat_id) — if Telegram is linked (Section 8).
  • Points on outcomes — who put how many points on which outcomes.
  • Technical connection data — IP address, browser headers, referral source, service logs.
  • Feedback-form submissions — text, page address, language, app version, browser data.
  • Consent records — what was accepted, when and in which revision.

No advertising; personal data is not sold.

3. The number and the birth date

Your number is computed from your date of birth (and time, if you provided it) by an open algorithm, and your date of birth — and, if a time was provided, the hour — can be recovered from the number. That is why your number is shown to others only with your separate consent to public display. After you claim a number — once your email address is confirmed — we ask you a separate question: you can allow your number to be shown in the registry (number page and registry search) and next to your signature in the chat and question comments — together or separately. Until you answer, and if you choose “Don't show”, your number is not shown to others. You can change your answer or withdraw consent in your account at any time — display stops immediately — or by writing to legal@papanumbers.com (within three business days). The date of birth itself is not published as a separate field. It cannot be changed after the number is claimed; if it was entered incorrectly, write to us.

4. Purposes and legal bases

What we doGDPR (EU users)Russian Law 152-FZ (Russian citizens)
Account, sign-in, registry, capsule delivery, chat, service e-mailsPerformance of a contract, Art. 6(1)(b)Contract with the data subject, Art. 6(1)(5)
Display of the number in the registry and next to the signature in the chat and comments — only with separate consent (Section 3)Consent, Art. 6(1)(a)Separate consent to dissemination, Art. 10.1
Weekly e-mailConsent, Art. 6(1)(a)Prior consent, Art. 18 of the Advertising Law
Telegram messages about question outcomesConsent, Art. 6(1)(a)Consent, Art. 6(1)(1)
Moderation, abuse protection, rate limitsLegitimate interest, Art. 6(1)(f)Art. 6(1)(7)
Visit statistics and product analytics (Section 12)Legitimate interest, Art. 6(1)(f)Art. 6(1)(7)
Compliance with legal requirementsLegal obligation, Art. 6(1)(c)Art. 6(1)(2)

You can unsubscribe from the weekly e-mail in any such e-mail or in your account.

5. Answers to questions and points on outcomes

Answers to questions are stored without your account identifier and are not linked to your profile. Breakdowns of answers are published only above thresholds: by country — from 50 respondents; public and research exports contain no personal data.

Points on outcomes are tied to your account: we store how many points you put on which outcomes. Points are a game unit (see the Terms of Use).

6. Time capsules

A capsule is stored until delivery; you grant us the right to store it for that entire time. If the addressee's number has not been claimed by anyone yet, the capsule waits until it is — with no time limit; you can withdraw it before delivery. A capsule addressed to another person undergoes a check for spam and abuse before delivery; letters to yourself are not checked.

On account deletion, a sealed capsule addressed to another person is still delivered on schedule — the link to the deleted account is erased and the content is not changed; a delivered capsule remains with the recipient; drafts and capsules to yourself are deleted. You are responsible for mentioning other people in a capsule.

The recipient of a capsule sees the sender's number in shortened form — the three leading digits, from which the birth year can only be estimated. The recipient sees the full number only if you chose this when sending.

7. Public chat and comments on questions

Chat and comments are public. The signature is your public name or, if you have none, “Participant N” (a participant number, not the registry number). The registry number is shown next to the signature only if you have allowed it to be shown in the chat and comments (Section 3).

We store the text, the time of sending and the link to the account. Chat messages are kept for 30 days; a comment is kept together with the question. You can delete your message or comment at any time; on account deletion they are deleted completely. They are not linked to answers to questions. Complaints are reviewed by a person; the author of a hidden message is notified with the reason.

8. Telegram

Linking Telegram is voluntary; when you unlink it in the settings, the chat_id is deleted. Messages about question outcomes are sent with your separate consent in your account, which you can withdraw at any time. Telegram is an independent service with its own rules. An account without an e-mail address is limited (Section 10).

9. Who we share data with

To run the service we engage providers: database and file storage (data centre in Ireland, EU), hosting, e-mail delivery, background jobs, abuse protection and statistics (USA; for abuse protection — IP address or technical identifier only, deleted within one day; for statistics — aggregate data and events without personal data, Section 12). They process data on our instructions; transfers outside the EU take place under the European Commission's Standard Contractual Clauses and, for some providers, also the EU-U.S. Data Privacy Framework. We will send you the full list of providers with transfer bases on request to legal@papanumbers.com.

Visitors from Russia. So that the site opens without a VPN, requests from Russia pass through our relay at a Russian provider; it stores nothing — it only forwards the request and returns the response.

We disclose data to public authorities only upon a lawful binding request and within its scope. For Russian citizens, transfers to these providers are cross-border transfers (Art. 12 of Law 152-FZ).

10. Retention and deletion

Your account is kept while you use it. Deletion — in the settings: a 30-day grace period with the option to restore, then the data is deleted permanently; anonymised aggregate statistics may be retained. An account without a confirmed e-mail address is limited and is deleted 12 months after registration, with a warning. No deletion releases the number — a new registration gives a different one. After the account is deleted, feedback-form submissions are kept without any link to it. Time capsules — until delivery, with no time limit (Section 6).

When an account is deleted, the consent log is deleted except for a minimal record: a cryptographic fingerprint of the e-mail address, the types of consents and refusals, their dates and the versions of the texts shown. We keep this record for three years to be able to prove, in a dispute, whether consent was given. It contains no account, IP address or answers, and can be matched to a person only if their e-mail address is known.

11. Your rights

You have the right to: access your data and obtain a copy (export in the service or on request); rectify profile data; delete your account; restrict processing; object to legitimate-interest processing; withdraw any consent; receive your data in a portable format. Requests — legal@papanumbers.com, reply within one month. Complaints: in the EU — your country's data protection authority (for the Netherlands, the Autoriteit Persoonsgegevens); in Russia — Roskomnadzor.

12. Cookies and statistics

We use minimal technical cookies (language, theme). There are no third-party advertising or tracking cookies; consent for technical cookies is not required.

To assess how the service works, we keep anonymised visit statistics (page address without parameters and without the number, referring site, browser and device type, country; no cookies; the visitor marker changes daily and is not stored) and count usage events (the action and its time — without birth date, e-mail, number, answers or page address; the IP address is not stored). The providers are in the USA; product-analytics events are stored in a data centre in the EU. Retention — no longer than 12 months. To opt out, use an ad blocker or "Do Not Track" in your browser.

13. Age

The service is available from the age of 18. We delete the account of anyone younger as soon as we learn of it.

14. Changes to this Policy

We may update this Policy. We will announce material changes at least 14 days in advance — on this page and by e-mail (or in Telegram if there is no address).

Privacy Policy · PapaNumbers