User Personal Data Processing Policy

1. General provisions
1.1. This Privacy and User Personal Data Processing Policy on the Internet resource ( (hereinafter referred to as the Policy) is developed by the Administration of 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
6.2. The User can at any time request the Personal Data Processor to destroy its personal data by contacting Maxmodal Support at 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

Last updated: April 30, 2020