Last updated 31 July 2026
This privacy notice for Watbot, LLC, the operator of Randogram (“Company,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@randogram.ru.
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
Who is the controller of your data? Watbot, LLC, a company incorporated in the Russian Federation (taxpayer number / INN 9718132634), registered at ul. Novozhenova, d. 90/1, pom. 302, Ufa, Republic of Bashkortostan, 450105, Russia. Learn more about how to contact us.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Randogram and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we collect payment card details? No. Card details are entered directly with our payment providers and never reach our servers. Learn more about payment data.
Do we receive any information from third parties? We receive payment status information from our payment providers and aggregated statistics from our analytics providers. We do not buy personal information from data brokers.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.
Where is your information stored? Our servers and databases are located in the Russian Federation. If you are in the European Economic Area, the United Kingdom, or Switzerland, this means your information is transferred outside your home jurisdiction. Learn more about international transfers.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
Want to learn more about what Randogram does with any information we collect? Review the privacy notice in full.
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW DO WE HANDLE INTERNATIONAL TRANSFERS?
6. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
7. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS NOTICE?
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
Sensitive Information. We do not process sensitive information.
Payment Data. If you purchase a paid subscription, your payment card details (card number, expiry date, security code) are entered directly with our payment provider and are never transmitted to or stored on our servers. We receive and store only the outcome of the payment, an opaque payment token (if you enable automatic renewal), and a masked card label consisting of the payment system and the last digits of the card number. All payment card data is stored by the payment provider you use.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location (based on your IP address), information about how and when you use our Services, and other technical information. When you sign in, we record the IP address, user agent, and timestamps of your sessions so that you can review and revoke active sessions. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.
Content you generate. Values you generate with our tools (such as random numbers, passwords, or documents) are produced for your use. We do not associate generated values with your account, and we do not use them for any purpose other than delivering the result to you.
Lists of draw entrants. The draw tool lets you upload a list of entrants and publishes it on a protocol page. You decide what goes into that list, and our terms require you to upload depersonalized data only — nicknames, ticket or entry numbers, initials — that cannot identify an individual without additional information. Uploading full names, phone numbers, email addresses, postal addresses or document details is not permitted. Before creating a draw you confirm that you are entitled to publish the list and that the entrants have been notified.
A protocol page is reachable only through its direct link, which carries a random identifier that cannot be guessed by enumeration. The page is excluded from search engines by a robots meta tag and by our robots.txt. Every protocol is stored for 1 months and is then deleted automatically together with the list of entrants. You may delete a protocol at any time in the "My draws" section of your account; deletion is irreversible. An entrant, or anyone else whose rights are affected by the publication, may request removal of a protocol by writing to privacy@randogram.ru.
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
We do not make decisions producing legal or similarly significant effects about you based solely on automated processing.
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
In legal terms, we are generally the "data controller" under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a "data processor" on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the "data controller" responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers' privacy practices, you should read their privacy policies and direct any questions you have to them.
EU/UK Representative
We have not appointed a representative under Article 27 of the GDPR because our processing of the personal data of individuals in the European Economic Area and the United Kingdom is occasional, does not involve large-scale processing of special categories of data or of data relating to criminal convictions and offences, and is unlikely to result in a risk to the rights and freedoms of individuals. We will appoint a representative if and when we become required to do so, and we will update this privacy notice accordingly.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
If you are located in the Russian Federation, this section applies to you.
We process your personal data in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data". Our Russian-language Personal Data Processing Policy sets out the mandatory disclosures required by that law, including the legal bases we rely on, retention and destruction periods, and the procedure for exercising your rights.
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
We also may need to share your personal information in the following situations:
We do not sell your personal information, and we do not share it for cross-context behavioral advertising in exchange for monetary consideration.
In Short: Our servers are located in the Russian Federation. If you use the Services from elsewhere, your information is transferred there.
We are established in the Russian Federation and our servers and databases are located there. If you access the Services from the European Economic Area, the United Kingdom, Switzerland, or any other region with laws governing data collection and use that may differ from Russian law, your personal information will be transferred to and processed in the Russian Federation.
The Russian Federation has not been the subject of an adequacy decision by the European Commission or the UK government. Where we transfer the personal data of individuals in the EEA or the UK to the Russian Federation, we rely on the derogations in Article 49 of the GDPR and UK GDPR, in particular that the transfer is necessary for the performance of the contract between you and us (Article 49(1)(b)) or, where applicable, on your explicit consent given after you have been informed of the possible risks of such transfer (Article 49(1)(a)).
Regardless of where your information is processed, we apply the safeguards described in "HOW DO WE KEEP YOUR INFORMATION SAFE?" below. If you do not wish your personal data to be transferred to the Russian Federation, please do not register for or use the Services.
In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.
The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Non-essential cookies are set only after you consent to them in our Cookie Consent Manager, and you can change or withdraw your choice at any time. Specific information about how we use such technologies, which providers are involved, how long cookies are stored, and how you can refuse certain cookies is set out in our Cookie Policy.
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). In particular:
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These include encryption of traffic between you and our Services (HTTPS), storage of passwords only as irreversible hashes, optional two-step authentication for your account, access control and least-privilege rules for our staff, logging and monitoring, and regular backups. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@randogram.ru.
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Canada, the Russian Federation, and certain US states, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws, and in any event within one month of receipt where the GDPR or UK GDPR applies, and within 10 working days where Russian law applies.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
If you are located in the Russian Federation, you may lodge a complaint with the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) at rkn.gov.ru.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate your account immediately and delete it and its information from our active databases after 30 days. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services, and you may change or withdraw your cookie consent at any time in our Cookie Consent Manager. For further information, please see our Cookie Policy.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
In Short: If you are a resident of a US state with a comprehensive consumer privacy law, you may have rights to access, correct, delete, and obtain a copy of your personal information, and to opt out of certain processing.
Several US states — including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and others — have enacted comprehensive consumer privacy laws. If you are a resident of such a state, you may have some or all of the following rights, subject to the exceptions in the applicable law:
Categories of personal information we collect. In the preceding twelve (12) months we have collected the following categories of personal information, as those categories are defined in the California Consumer Privacy Act (CCPA):
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, etc | YES |
| B. Personal information categories listed in the California Customer Records statute | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES (name and billing address only) |
| C. Protected classification characteristics under California or federal law | Race, color, national origin, religion, sex, age, disability, citizenship status, genetic information, marital status, medical conditions, or sexual orientation | NO |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES (subscription and payment history) |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES (interaction with our Services and, subject to your cookie consent, analytics data) |
| G. Geolocation data | Physical location or movements. | YES (approximate country and region derived from your IP address only) |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information | Current or past job history or performance evaluations. | NO |
| J. Education Information | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information | Preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | NO |
| L. Sensitive personal information | Account log-in credentials, precise geolocation, racial or ethnic origin, contents of communications, and similar information. | NO |
We retain each category for the periods set out in "HOW LONG DO WE KEEP YOUR INFORMATION?" above.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
How do we use and share your personal information?
We disclose personal information to the categories of service providers listed in "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" for the business purposes described in this notice. Each service provider is bound by a written contract that requires it to process the information only on our instructions and to apply the protections mandated by applicable law.
Where you consent to targeting cookies, the categories A, F, and G may be disclosed to the advertising and analytics providers identified in our Cookie Policy. Some US state laws treat this kind of disclosure as a "sale" or "sharing" of personal information. You can prevent it entirely by rejecting targeting cookies in our Cookie Consent Manager.
Randogram has not sold personal information for monetary consideration in the preceding twelve (12) months and will not do so in the future.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
California "Shine The Light" law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
How to exercise your rights
You may contact us by email at privacy@randogram.ru, by visiting randogram.ru/contact, or by referring to the contact details at the bottom of this Privacy Notice.
You can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Response times and right to appeal
Upon receiving your request, we will respond without undue delay, and in all cases within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary; we will inform you of any such extension within the initial 45-day period, together with the reason for the extension.
If we decline to take action regarding your request, we will inform you of our decision and the reasoning behind it. If you wish to appeal our decision, please email us at privacy@randogram.ru. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If your appeal is denied, you may contact your state Attorney General to submit a complaint.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may contact the person responsible for the organization of personal data processing by email at privacy@randogram.ru, or by post at the address below:
Name: Watbot, LLC
Taxpayer number (INN): 9718132634
Tax registration reason code (KPP): 027601001
State registration number (OGRN): 1197746194601
Registered address: ul. Novozhenova, d. 90/1, pom. 302, Ufa, Republic of Bashkortostan, 450105, Russia
Website: randogram.ru
Support email: support@randogram.ru
Privacy email: privacy@randogram.ru
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit Personal account or email us at privacy@randogram.ru.