User Personal Data Processing Policy
1. General provisions1.1. This Privacy and User
Personal Data Processing Policy on the
maxmodal.com Internet
resource (
https://maxmodal.com/privacy) (hereinafter
referred to as the Policy) is developed by the Administration of
https://maxmodal.com
and determines the procedure and conditions for processing by the Administration of User personal data.
1.2.
This Policy is an integral part of the User Agreement, and it uses the general terms and definitions as defined in
the User Agreement.In the event of a conflict between the provisions of this Policy and the User Agreement, the
rules of this Policy shall prevail.
1.3. This Policy applies to all information that the Administration and /
or its affiliates may receive about the User while using Maxmodal.
1.4. The use of Maxmodal means the
unconditional consent of the User with this Policy and the conditions for processing its personal data specified in
it; in case ofdisagreement with these conditions, the User should refrain from using Maxmodal.
1.5. The moment
of expressing consent to the processing of the user 's personal data in the context of the Federal Law of July 27,
2006 No. 152-ФЗ “On Personal Data” (hereinafter referred to as the Law) is the moment of registration with Maxmodal,
and in relation to personal data specified in clause 4.1.10. of this Policy - the moment of continued use of
Maxmodal after reviewing the information on the use of such data (to achieve the goals stipulated by clauses
2.2.4-2.2.6 of this Policy)/the moment of registration with Maxmodal (to achieve the goals stipulated by clauses
2.2.1-2.2.3. of this Policy).
User personal data shall be processed in accordance with the Law.
1.6. The
Personal Data Processor shall be entitled to make changes to this Policy.When making changes in the current edition,
the date of the last change is indicated.The new version of the Policy comes into force from the moment it is
posted, unless otherwise provided by the new version of the Policy.
1.7. The law of the Russian Federation
shall apply to this Policy and the relationship between the User and the Personal Data Processor arising in
connection with the application of this Policy.
1.8. The administration recommends that Users regularly check
the terms of this Policy for changes and / or additions.Continued use of Maxmodal by the User after making changes
and / or additions to this Policy means acceptance and consent of the User to such changes and / or additions.
1.9. The following terms and definitions apply in this Policy:
User - both the User in the
context of the definition set forth in the User Agreement, and other visitors to Maxmodal prior to their
registration on Maxmodal.
Personal data - any information relating directly or indirectly to
a defined or determinable natural person - to the Maxmodal User (personal data subject).
Personal data
processor — Digital EcoSystems LLC.
Personal data processing - any action
(operation) or a set of actions (operations) performed using automation tools or without using such tools with
personal data, including collection, recording, systematization, accumulation, storage, clarification (updating,
modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion,
destruction of personal data.
Confidentiality of personal data — the obligation of the
Personal Data Processor and other persons who have gained access to personal data not to disclose to the third
parties and not to distribute personal data without the consent of the personal data subject, unless otherwise
provided by federal law.
Automated processing of personal data - personal data processing
using computer technology;
Distribution of personal data - actions aimed at the disclosure
of personal data to an indefinite number of persons;
Provision of personal data - actions
aimed at disclosing personal data to a specific person or a certain number of persons;
Blocking of
personal data - temporary suspension of personal data processing (unless processing is necessary to
clarify personal data);
Destruction of personal data - actions, as a result of which it
becomes impossible to restore the content of personal data in the personal data information system and/or as a
result of which material carriers of personal data are destroyed;
Depersonalization
of personal
data - actions, as a result of which it becomes impossible without the use of additional information to
determine belonging of personal data to a specific subject of personal data;
Personal data information
system - a set of personal data contained in databases and information technologies and technical means
that ensure their processing;
Cross - border transfer of personal data — the transfer of
personal data to the territory of a foreign state to a foreign government authority, a foreign individual or a
foreign legal entity.
Other terms, definitions and phrases used in this Policy have meaning and are subject to
interpretation in accordance with the provisions of the User Agreement, the established practice of using these
terms, definitions and phrases when working in the field of Internet technologies, as well as in accordance with the
current legislation of the Russian Federation, including with the Law.
2. Purpose of collecting and
processing personal data 2.1. Personal Data Processor collects and stores only those personal data
that are necessary for the provision of services provided using Maxmodal and its individual functions / services.
2.2. The Personal Data Processor may use personal data for the following purposes:
2.2.1. User
identification, including during registration.
2.2.2. Providing the User with personalized services and
services.
2.2.3. Communication with the User, including sending of notifications, requests and information
regarding the use of Maxmodal, the provision of services, as well as processing of requests and applications from
the User.
2.2.4. Improving the quality of Maxmodal, ease of use, development of new services.
2.2.5.
Targeting promotional materials.
2.2.6. Conducting statistical and other studies based on depersonalized data.
3. Legal grounds for personal data processing The legal grounds for personal data
processing are:
—Civil Code of the Russian Federation;
—Federal Law“ On Information, Information
Technologies and Information Protection”;
—Charter of Digital EcoSystems LLC;
—consent to personal data
processing received from the User in the manner prescribed by this Policy.
4. Scope and categories of
processed personal data, categories of subjects of personal data 4.1. The Personal Data Processor
processes the following personal data:
4.1.1. Name.
4.1.2. Surname.
4.1.3. Phone number.
4.1.4. E
- mail address.
4.1.5. Patronymic.
4.1.6. City of residence.
4.1.7. Date of birth.
4.1.8. Photo.
4.1.9. Places of work.
4.1.10. Data that Maxmodal automatically transmits during its use using the software
installed on the User’ s device: cookies, user data(location information; OS type and version; browser type and
version; device type and screen resolution; source from where the user came from; from which site or by which
advertisement; language of the operating system and browser; which pages it opens and which buttons the user clicks;
ip - address)
At the same time, personal data specified in clauses 4.1.5. - 4.1.9. of this Policy are not
mandatory, and are provided by the User at will.
4.2. Personal data specified in clauses 4.1.1. - 4.1.10. of
this Policy belong to the category of “other personal data”, including the photo image, as it is not used to
identify the User.
4.3. The Personal Data Processor processes personal data of the following categories of
personal data subjects:
4.3.1. Clients and counterparties of the Personal Data Processor(natural persons,
individual entrepreneurs).
4.3.2. Representatives / employees of clients and counterparties of the Personal
Data Processor(legal entities).
5. Personal data processing procedure and conditions 5.1.
The Personal Data Processor stores the personal data of Users in accordance with the internal regulations of the
Data Processing Center located on the territory of the Russian Federation - Data Line LLC, with which the Personal
Data Processor has concluded an appropriate agreement.Using Maxmodal, the User thereby expresses its consent to the
personal data transfer to the specified legal entity for storage and other actions related to storage.
5.2. The
Personal Data Processor keeps personal data confidential, except in cases where the user voluntarily provides
information about itself for general access to an unlimited number of people, as well as to inquiry and
investigation bodies, other authorized bodies on the grounds provided for by the current legislation of the Russian
Federation.
5.3. The Personal Data Processor is entitled to transfer personal data to the third parties in the
following cases:
5.3.1. The user has expressed its consent to such actions.
5.3.2. The transfer is necessary
as part of the User’ s use of a particular service or to provide a service to the User, and the User is aware that
such a transfer will be made if a certain service is used or to provide a service.
5.3.3. The transfer is
provided for by Russian or other applicable legislation within the framework of the procedure established by law,
including in accordance with the Law.
5.3.4. Such a transfer takes place as part of a sale or other transfer of
business( in whole or in part), and all obligations to comply with the terms of this Policy with respect to the
personal data received by the acquirer shall pass to it.
5.3.5. In order to ensure the possibility of
protecting the rights and legitimate interests of the Personal Data Processor or the third parties in cases where
the User violates the User Agreement or certain documents constituting its integral parts.
5.4. Within the
framework of achievement of the goals specified in clause 2 of this Policy, the Personal Data Processor can carry
out the following actions with personal data: collection, recording, systematization, accumulation, storage,
clarification(updating, change), extraction, use, transfer(distribution, provision, access), depersonalization,
blocking, deletion, destruction of personal data.
5.5. Using Maxmodal, the User thereby expresses its consent
to the distribution of personal data to an unlimited number of Maxmodal Users, except for the personal data
restricted by the User for distribution through the establishment of special Maxmodal privacy settings.
5.6.
The Personal Data Processor processes personal data through automated processing of personal data.
5.7.
Personal data processing shall be terminated if the User withdraws its consent to personal data processing submitted
in writing - by e - mail or to the legal address of the Personal Data Processor, as well as by means of the User
taking specific actions– deletion of its account.
5.8. Personal data processing may also be terminated by the
decision of the Personal Data Processor as part of the application of the liability measures set forth in clause
4.1. of the User Agreement.
5.9. The storage period for personal data cannot exceed a reasonable period required
for destruction of personal data in the case provided for in clause 5.7. of this Policy, unless:
5.9.1.
Otherwise is provided for by the contract, a party, a beneficiary or a guarantor to which is the personal data
subject.
5.9.2. Otherwise is provided for by another agreement between the Personal Data Processor and the
personal data subject.
6. Updating, correction, deletion and destruction of personal data, responses
to requests from subjects for access to personal data 6.1. The User can at any time update, correct,
delete the personal data provided by it or a part of them, as well as change the privacy settings by using the
personal information editing function in its personal account or by writing to Maxmodal support at
compliance@maxmodal.com.
6.2. The User can at any
time request the Personal Data Processor to destroy its personal data by contacting Maxmodal Support at
compliance@maxmodal.com or the legal address of the
Personal Data Processor specified in the User Agreement.
6.3. The Personal Data Processor can decide to refuse
to delete / destroy personal data if the User has unfulfilled obligations to the Administration or other Users.At
the same time, the Personal Data Processor is obliged to delete the personal data of such User in the event that it
fulfills obligations in full.
6.4. The User shall be at any time entitled to withdraw its demand to terminate
the use and / or deletion / destruction of personal data before the Personal Data Processor carries out the relevant
actions.
6.5. Upon receipt by the Personal Data Processor of any request from the User, the Personal Data
Processor shall be entitled to request confirmation of sending such a request from the User if there is a reason to
believe that such a request was sent on behalf of the User by the third parties not duly authorized therefore.
6.6.
The Personal Data Processor takes the necessary and sufficient organizational and technical measures to protect
personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as
well as from other illegal actions of the third parties with them.
6.7. The User is aware that creating
restrictions on the Personal Data Processor in personal data processing, deleting personal data, destroying personal
data at the request of the User may result in inability to use Maxmodal or its individual functionality / services.
6.8. Any suggestions or questions regarding this Policy should be reported to Maxmodal Support at
compliance@maxmodal.com. Last updated: April
30, 2020