Privacy Policy
Revision of 17 September 2026. Effective from the date of publication on this page. This is a binding document; 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 controller's EU representative (Art. 27 GDPR) is Maksym Samokhin (the Netherlands). Contact for all data matters: legal@papanumbers.com; we reply within one month. Once a legal entity is incorporated, the controller's rights and obligations will pass to that legal entity — we will announce the transition in advance on this page and by e-mail.
2. What data we process
- E-mail address — account, sign-in, access recovery, e-mails.
- Birth date — your number is computed from it (Section 3).
- Country — for country-level answer breakdowns.
- Public handle — optional, at your choice.
- Time-capsule content — text, sometimes photos (Section 6).
- Public chat messages, comments on questions and reactions (Section 7).
- Telegram identifier (chat_id) — if you link Telegram (Section 8).
- Point stakes — which account staked how many points on which outcomes.
- Technical connection data — IP address, browser headers, service logs.
- Feedback-form submissions — the text, page address, interface language, app version and browser data; the reply arrives in "My mail" in your account.
- Consent records — what you accepted, when, and in which revision.
We do not show ads and do not sell personal data.
3. The number and the birth date
Your number is computed from the birth date by an open algorithm and is public — the birth date can be recovered from the number. By claiming a number you understand this; publication of the number in the registry and showing it next to your signature in the chat and comments (Section 7) take place under your separate consent, given by a separate action when you claim it and revocable at any time (legal@papanumbers.com or account deletion). The birth date itself is not published as a separate field. It cannot be changed after claiming; if it was entered incorrectly, write to us.
4. Purposes and legal bases
| What we do | Basis — GDPR (EU users) | Basis — Russian Law 152-FZ (Russian citizens) |
|---|---|---|
| Account, sign-in, registry operation, capsule delivery, chat, service e-mails | Performance of a contract, Art. 6(1)(b) | Contract with the data subject, Art. 6(1)(5) |
| Publication of the number in the registry and showing it in the signature | Consent, Art. 6(1)(a) | Separate consent to dissemination, Art. 10.1 |
| Weekly letter | Consent, Art. 6(1)(a) | Prior consent, Art. 18 of the Advertising Law |
| Telegram messages about question outcomes | Consent, Art. 6(1)(a) | Consent, Art. 6(1)(1) |
| Moderation, abuse protection, rate limiting | Legitimate interest, Art. 6(1)(f) | Art. 6(1)(7) |
| Compliance with legal requirements | Legal obligation, Art. 6(1)(c) | Art. 6(1)(2) |
The weekly letter is sent only with your separate consent (never a pre-ticked box); you can unsubscribe from any such e-mail or in your account. You may object to processing we carry out in our own legitimate interest (moderation, abuse protection) — write to legal@papanumbers.com (Section 11).
5. Answers and stakes
Answers to questions are stored without your account identifier and are not joined to your profile. Demographic breakdowns of answers are published only above thresholds: by country — from 50 respondents; public and research exports contain no personal data.
A stake works differently: it is linked to your account — we store how many points you staked and on which outcomes. Points are a game unit: they cannot be bought, withdrawn or transferred (see the Terms).
6. Time capsules
A capsule is stored until its appointed delivery date; you grant us the right to store it for that entire time. 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. If you mention other people in a capsule, you are responsible for the lawfulness of doing so.
7. Public chat and comments on questions
The chat and comments on questions are public: everything you write is visible to other members. A message or comment is signed with your public handle, or, if you have not set one, with "Participant N", where N is a participant number, not your registry number. If you have consented to showing your number in the registry (Section 3), your number is shown next to the signature as well; once consent is withdrawn, the number is no longer shown in the signature.
We store the text, the time of sending and the link to your account. Chat messages are stored for 30 days and then deleted; a comment is stored together with its question. You can delete your message or comment at any time; deleting your account deletes them entirely. Answers to questions are joined neither to the chat nor to comments. Reports are decided by a human; the author of a hidden message or comment is notified with the reason.
8. Telegram
Linking Telegram is voluntary; you can unlink it in the settings — we then delete the chat_id. With your separate consent (a checkbox in your account) we send you a Telegram message when a question you answered gets an outcome; you can untick it at any time. Telegram is an independent service: messages pass through its infrastructure under its rules. An account created via Telegram 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 hosted in a data centre in Ireland, EU), hosting, e-mail delivery, background jobs and abuse protection (USA; for abuse protection — IP address or technical identifier only, deleted within one day). They process data on our instructions and do not use it for their own purposes; 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 — write to legal@papanumbers.com. If we engage a provider for automated text checks, we will announce it here before the first transfer.
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 under 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 (restorable), then the data is deleted permanently; anonymized aggregate statistics may be retained. An account without a confirmed e-mail address is limited and is deleted 12 months after registration — we will warn you beforehand by e-mail, or by a Telegram message if there is no address. No deletion ever releases the number — a new registration gives you a different one. Feedback-form submissions are kept for as long as your account exists. Export of your data — in the service or via legal@papanumbers.com.
11. Your rights
You have the right to: access your data and obtain a copy (export); rectify profile data; delete your account; restrict processing; object to legitimate-interest processing; withdraw any consent; receive your data in a portable format. The birth date cannot be "rectified" after claiming — you can delete the account and register again (with a different number). 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
We use minimal technical cookies (for example, language and theme). There are no third-party advertising or tracking cookies; consent for technical cookies is not required.
13. Age
The service is available to persons aged 18 or over. We do not knowingly process the data of anyone younger; if we learn of such an account, we delete 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).