Политика обработки данных

POLICY FOR THE COLLECTION AND PROCESSING OF "COOKIE" FILES AND METRIC DATA

OF THE "MIX-SMM.RU" PLATFORM

Russia, Tula

July 1, 2026

This policy, in accordance with Part 2 of Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data", defines the policy of the operator of the "MIX-SMM.RU" Platform, which is: an individual, Kolganov Pavel Aleksandrovich, who is a payer of the professional income tax (self-employed), INN 710402814358, address: Russia, Tula Region, Tula, Sedova St. 35b, apt. 54 (hereinafter referred to as the Operator) regarding the processing of "cookie" files and metric data that it may receive from the User during the use of the Platform. This policy is an integral part of the Operator's internal document defining the Operator's general policy regarding the processing of personal data and disclosing general information about the Operator's implemented requirements for the protection of personal data.

1. GENERAL PROVISIONS

1.1. The following terms and definitions for the purposes of this policy have the following meaning:

"Platform", "Information System" – the Internet resource "MIX-SMM.RU", designed for automated placement by the User of orders for SMM services and management of such orders, access to which is provided by the Operator to Users at the addresses: https://mix-smm.ru (main domain), https://mix-smm.ru/en (English version), https://guide.mix-smm.ru/ (backup URL).

"User" – any natural person using the Platform (including visiting open pages of the Platform) on their own behalf or on behalf of another natural or legal person they represent, possessing the appropriate authority, having free access to the Internet, including the ability to use the Platform.

"Agreement" – a user or other agreement between the User and the Operator regulating the procedure for using the Platform.

"Cookie files", "cookies" – a small piece of data sent by a web server and stored on the User's device. Cookie files contain small pieces of text and are used to store information about browser operations. They allow storing and receiving identification information and other information on computers, smartphones, phones and other devices. Cookie specifications are described in RFC 2109 and RFC 2965 documents. For these same purposes, other technologies are used, including data stored by browsers or devices, identifiers associated with devices, and other software. In this policy, all these technologies are referred to as "cookie" files.

"Web beacons", "Pixels" – images in electronic form (single-pixel (1x1) or empty GIF images). Web beacons can help the Operator recognize certain types of information on the User's device, such as cookie files, the time and date of page view, and a description of the page where the web beacon is placed.

"Counter" – a computer program using a piece of code installed on a web service, responsible for analyzing cookie files and collecting statistical and personal data of this web service. The collection of personal data is carried out in an anonymized form.

"IP-address" – a number from the numbering resource of a data transmission network built on the basis of the IP protocol (RFC 791), uniquely identifying, in the provision of telematics communication services, including Internet access, a subscriber terminal (computer, smartphone, tablet, other device) or communication means included in the information system and belonging to the User.

1.2. All other terms and definitions found in the text of this policy are interpreted by the Parties in accordance with the legislation of the Russian Federation, current recommendations (RFC) of international standardization bodies on the Internet and the usual rules of interpretation of relevant terms established on the Internet.

1.3. The terms and definitions used in this policy may be used in both singular and plural depending on the context, and the spelling of terms may be used with both capital and lowercase letters.

1.4. This policy defines the procedure and conditions for the Operator's use of cookie files and metric data collection technologies, including the transfer of received data to third parties, features of automated information processing, the procedure for accessing collected data, the system for protecting such data, the organization of internal control and liability for violations of the procedure for their processing, as well as other issues regarding the handling of cookies and metrics.

1.5. This policy applies to all processes for the use of cookie files and collection of metric data carried out on the Platform, both with and without the use of automation tools. The Operator does not control and is not responsible for third-party websites to which the User may follow links posted on the Platform.

1.6. This Policy is an integral part of the Operator's internal document regulating the processing of Users' personal data and applies together with the Privacy Policy posted at: https://mix-smm.ru/policy to the extent not contradictory.

2. COMPOSITION OF PROCESSED DATA

2.1. Personal data processed in accordance with this policy and automatically transmitted to the Operator during the use of the Platform using the software installed on the User's device may include the following information:

2.1.1. IP-address of the User's device;

2.1.2. HTTP headers;

2.1.3. cookie data;

2.1.4. data collected by counters;

2.1.5. data obtained using web beacons;

2.1.6. information about the User's browser;

2.1.7. technical characteristics of the device and software;

2.1.8. date and time of access to the Platform;

2.1.9. addresses of requested Platform pages;

2.1.10. geographical coordinates of the User's location.

3. TYPES OF "COOKIE" FILES

3.1. The Operator uses various types of "cookies" on the Platform, which serve different purposes and, depending on them, may fall into one of the following categories:

3.1.1. "Strictly Necessary", i.e., cookie files that are strictly necessary for the functioning of critical components of the Platform.

3.1.2. "Functional", i.e., cookie files that allow the User to interact with the Platform interface and use its capabilities, record information about actions performed on the Platform and configure the Platform according to the User's needs. Without these cookie files, the Platform will not be able to provide certain functions, such as remembering information entered by the User, saving the preferred language, etc.

3.1.3. "Analytical", i.e., analytical/statistical cookie files that help improve the performance of the Platform and make it more convenient for Users. Through Analytical cookie files, the Operator receives information about the quality and/or efficiency of the Platform and its services, which helps understand how Users use the Platform and how they use the Operator's services.

4. PROCEDURE FOR COLLECTING PERSONAL DATA USING "COOKIE" FILES

4.1. Cookie files transmitted from the Operator to the User's device and from the User to the Operator may be used by the Operator to achieve the purposes of processing personal data in accordance with the privacy and personal data processing policy.

4.2. The Operator has the right not to explicitly request consent when using strictly necessary cookie files. If the User does not wish their personal data to be collected using strictly necessary cookie files, they may disable their provision to the Operator in the software (browser) on their device. At the same time, the User will no longer have access to the Platform's functionality related to strictly necessary cookie files, which may lead to complete inoperability or incorrect operation of the Platform.

4.3. The Operator may use functional and analytical cookie files only with the User's consent, which is generally expressed by acceptance of the Agreement and commencement of use of the Platform. Otherwise, the User has the right to refuse the use of such cookie files by disabling them in the Platform or browser settings without harm to its functionality.

4.4. The User agrees that their devices and software used to work with the Platform, depending on their version and configuration, may or may not have the function of prohibiting operations with cookie files for any or specific sites and applications, as well as the function of deleting previously received cookie files (for example, private browser mode).

4.5. The Operator has the right to establish a requirement for the User's device to mandatorily allow the acceptance and receipt of cookie files due to security requirements.

4.6. The structure of the cookie file, its content and technical parameters are determined by the Operator and may be changed without prior notice to the User. The User has the right to receive all necessary information about cookie files by sending a request to the Operator in the manner established by the privacy and personal data processing policy.

5. PROCEDURE FOR COLLECTING PERSONAL DATA USING WEB BEACONS AND COUNTERS

5.1. Counters placed by the Operator on the Platform may be used by the Operator to analyze cookie files and collect personal data about the use of the Platform in order to improve the quality of the Platform, the level of its usability, and improve the Platform. The technical parameters of the counters' operation are determined by the Operator and may be changed without prior notice to the User.

5.2. The Operator may also use web beacons either separately or together with cookie files to collect information about the use of the Platform. The User has the right to block web beacons when using the Platform by prohibiting the loading of images in the settings of their software (browser).

5.3. Use of third-party web analytics and marketing services:

5.3.1. The Platform has installed counter codes and web beacons belonging to third parties. These services may collect anonymized data on traffic, User behavior on the Platform, device type and browser.

5.3.2. The Operator uses the following services:

Yandex.Metrica (YANDEX LLC), counter No. 90815712. Used for statistical accounting of traffic and session recording.

5.3.3. Data collected by these services (counters, web beacons) may be transmitted to servers under the control of the respective companies. The User may block the operation of these counters using browser settings or special extensions (ad blockers), which may affect the ability to view Platform content.

6. OBTAINING AND PROCESSING THE USER'S IP ADDRESS

6.1. During the use of the Platform, the Operator automatically receives the IP address of the User's device. The receipt of the IP address is carried out through:

6.1.1. Loading Platform pages and interacting with Platform elements;

6.1.2. Use of cookie files, counters, web beacons and other web analytics tools;

6.1.3. In the process of the User sending feedback forms and other appeals through the Platform.

6.2. The IP address is used by the Operator for the following purposes:

6.2.1. technical support for the functioning of the Platform;

6.2.2. conducting internal audit, analysis and statistics of Platform usage;

6.2.3. protection against unauthorized access and unlawful actions, detection and prevention of fraud and other abuses;

6.2.4. compliance with the requirements of the legislation of the Russian Federation.

6.3. The IP address is processed automatically in an anonymized form, unless otherwise expressly provided by applicable legal requirements.

6.4. Within the framework of using the web analytics services specified in clause 5.3.2. of this policy, the IP address may also be transmitted to third-party services in an anonymized or shortened (anonymized) form in accordance with the established rules of the services themselves.

6.5. The Operator does not match the IP address with other personal data of the User, unless otherwise provided for by the Agreement or legal requirements.

6.6. The processing period for the IP address corresponds to the periods established for storing cookie files and other metric data. After these periods expire, data about the User, including the IP address, is subject to deletion or anonymization.

7. FINAL PROVISIONS

7.1. This policy comes into force from the moment of its approval by the Operator and is valid indefinitely until replaced by a new version.

7.2. The Operator has the right to make changes to this policy without the User's consent. All changes are made by an administrative act of the Operator.

7.3. The User's commencement of use of the Platform means their consent to the terms of this policy. In case of disagreement with the terms of this policy, the use of the Platform must be immediately terminated.

7.4. The law of the Russian Federation shall apply to this policy and to the relations between the User and the Operator arising in connection with the application of this policy.

7.5. This policy is in constant open access on the Platform at the following link: https://mix-smm.ru/en/policy.

7.6. The User has the right to send all suggestions or questions about this policy to the Operator's user support service by sending an electronic message to the email address: maxpanel@mail.ru.

OPERATOR'S DETAILS

Kolganov Pavel Aleksandrovich

(self-employed)

INN: 710402814358

Address: 300028, Russia, Tula Region, Tula, Sedova St. 35b, apt. 54.

Email: maxpanel@mail.ru

OF THE "MIX-SMM.RU" PLATFORM

Russia, Tula

July 1, 2026

This policy, in accordance with Part 2 of Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data", defines the policy of the operator of the "MIX-SMM.RU" Platform, which is: an individual, Kolganov Pavel Aleksandrovich, who is a payer of the professional income tax (self-employed), INN 710402814358, address: 300028, Russia, Tula Region, Tula, Sedova St. 35b, apt. 54 (hereinafter referred to as the Operator) regarding the processing of personal data and contains information about the Operator's implemented requirements for the protection of personal data.

The Policy applies to all personal data processed using the Platform that the Operator receives or may receive from the User. The Policy is an integral part of the Operator's internal document defining the Operator's general policy regarding the processing of personal data and disclosing general information about the Operator's implemented requirements for the protection of personal data.

1. GENERAL PROVISIONS

1.1. The following terms for the purposes of this policy shall have the following meanings:

"Automated processing of personal data" – processing of personal data using computer technology.

"Blocking of personal data" – temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).

"Use of personal data" – actions (operations) with personal data performed for the purpose of making decisions, concluding transactions or other actions that give rise to legal consequences in relation to the subjects of personal data or otherwise affect their rights and freedoms or the rights and freedoms of other persons.

"Confidentiality of personal data" – a requirement mandatory for a person who has gained access to personal data not to allow their dissemination without the consent of the subject or other legal grounds.

"Non-automated processing of personal data", "Processing of personal data without the use of automation tools" – processing of personal data contained in a personal data information system or extracted from such a system in cases where actions with personal data, such as use, clarification, distribution, destruction of personal data in relation to each of the subjects of personal data, are carried out with the direct participation of a person.

"Processing of personal data" – actions (operations) with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction.

"Publicly available personal data" – personal data to which access by an unlimited number of persons is provided with the consent of the subject or to which the requirement of confidentiality does not apply in accordance with federal laws.

"Personal data" – any information relating directly or indirectly to an identified or identifiable on the basis of such information natural person (subject of personal data); an identifiable natural person is a person who can be identified directly or indirectly, in particular, by reference to an identifier, such as name, surname, email address, phone number and other data that is transmitted to the Operator during the use of the Platform using the software installed on the User's Device (including location data, HTTP headers, IP address, cookie data, information about the User's browser, technical characteristics of the hardware and software used by the User, date and time of access to the Platform, addresses of requested Platform pages and other similar information), one or more physical, physiological, genetic, spiritual, economic, cultural factors characteristic of the specified person or by reference to factors of social identity. In addition, for the purposes of this policy, personal data also includes information about the User, the processing of which is provided for by the Agreement regulating the procedure for using the Platform. In accordance with Decree of the President of the Russian Federation No. 188 of March 6, 1997, personal data belongs to confidential information. The Operator collects only such personal data that is necessary for the execution of the Agreement.

"Transfer of personal data" – actions aimed at transferring personal data to a specific person or a specific circle of persons.

"Dissemination of personal data" – actions aimed at disclosing personal data to an indefinite circle of persons.

"Agreement" – a service agreement, user or other agreement between the User and the Operator or between Users of the Platform, regulating the procedure for using the Platform, concluded either by signing it or by performing the conclusive actions specified therein aimed at using the Platform.

"Statistics" – information about the use of the Platform, as well as about the viewing by Users of individual elements of the Platform (web pages, frames, content, etc.), collected using Counters, cookie files, web beacons and other similar technologies.

"Token" – a unique set of characters identifying the User in accounts of third-party web services. The token allows authorized connection to the Platform using authorization through third-party web services (for example, social networks, Google Play, Apple AppStore and others).

"Destruction of personal data" – actions as a result of which it is impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed.

"Device", "User's Device" – a computer, mobile device or virtual machine based on an operating system with a web browser installed that is compatible with the Platform.

"Applicable Law" – the legislation of the country in which the Operator is registered or of which it is a resident (the legislation of the Russian Federation). In certain cases, applicable law may mean the legislation of the country in which the User resides or of which they are a resident, if such legislation establishes the priority of its norms over the rules of this policy.

1.2. All other terms and definitions found in the text of the Policy are interpreted by the Parties in accordance with the legislation of the Russian Federation, the User Agreement and other documents of the Operator, current recommendations (RFC) of international standardization bodies on the Internet and the usual rules of interpretation of relevant terms established on the Internet.

1.3. The terms and definitions used in the policy may be used in both singular and plural depending on the context, and with both capital and lowercase letters.

1.4. The Policy is developed in accordance with the Constitution of the Russian Federation, the Civil Code of the Russian Federation, Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Information Protection", Federal Law No. 152-FZ of July 27, 2006 "On Personal Data", other federal laws and legal acts.

1.5. The Policy defines the procedure and conditions for the processing of personal data by the Operator, including the procedure for transferring personal data to third parties, features of non-automated processing of personal data, the procedure for access to personal data, the system for protecting personal data, the procedure for organizing internal control and liability for violations in the processing of personal data, as well as other issues.

1.6. The Policy comes into force from the moment of its approval by the Operator and is valid indefinitely until replaced by a new policy.

1.7. The Operator has the right to make changes to the policy without the User's consent. All changes to the policy are made by an administrative act of the Operator.

1.8. The Policy applies to all processes for the processing of personal data carried out using the Platform, both with and without the use of automation tools. The Operator does not control and is not responsible for third-party websites to which the User may follow links posted on the Platform.

2. LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL DATA

2.1. The Operator processes the User's personal data, guided by international acts in the field of personal data protection, acts of applicable law, and, in relation to Users located on the territory of the Russian Federation, by Law No. 152-FZ.

2.2. The processing of the User's personal data is carried out by the Operator only if the User has reached the age of 18. If the User is under 18 years of age, the mandatory consent of the User's legal representatives is required; otherwise, upon detection of age non-compliance, the Operator deletes the User's data from the Platform. If the requirements of applicable law establish a lower or higher age, the provisions of applicable law shall apply.

2.3. The processing of the User's personal data is carried out on the basis of and in execution of the Agreement regulating the procedure for using the Platform and other agreements or contracts concluded between the User and the Operator.

2.4. The processing of the User's personal data may be carried out on the basis of their separate consent to such processing, which may be expressed, inter alia, directly when using the Platform by clicking the appropriate button or by placing a checkmark in the corresponding checkbox. The period of validity of such User consent is indicated in its text.

3. PURPOSES OF COLLECTING PERSONAL DATA

3.1. The Operator processes only those personal data that are necessary for the use of the Platform or the execution of agreements and contracts with the User, except in cases where the legislation of the Russian Federation provides for the mandatory storage of personal information for a certain period established by law, in particular in accordance with accounting legislation and the rules for organizing state archival affairs.

3.2. When processing personal data, the Operator does not combine databases containing personal data, the processing of which is carried out for incompatible purposes.

3.3. The Operator processes the User's personal data for the following purposes:

3.3.1. use of Users' personal data for the purposes of concluding and executing the Agreement or any other agreement with the Operator or between Users of the Platform;

3.3.2. use of Users' personal data for the purposes of proper functioning of the Platform in accordance with Users' expectations, in particular for the correct identification of Users, provision of technical support, if the result depends on the data provided;

3.3.3. conducting statistical and other studies of the use of the Platform based on metric data;

3.3.4. conducting the affiliate program, marketing programs, various offers, promotions and advertising events related to the Platform.

4. SCOPE AND CATEGORIES OF PROCESSED PERSONAL DATA, CATEGORIES OF PERSONAL DATA SUBJECTS

4.1. The Operator may receive the User's personal data from various sources, in particular:

4.1.1. from the Platform during its operation;

4.1.2. upon the User's registration on the Platform;

4.1.3. when placing an Order;

4.1.4. when contacting the Operator, including the Platform's technical support service;

4.1.5. when the User participates in the affiliate program, various offers, promotions and advertising events of the Operator related to the Platform.

4.2. Personal data permitted for processing in accordance with the policy and provided by Users who are natural persons using the Platform both on their own behalf and on behalf of the individual entrepreneur or legal entity they represent, by filling in the relevant input fields when using the Platform, may include the following information:

4.2.1. Use of Users' personal data for the purposes of concluding and executing the Agreement or any other agreement with the Operator or between Users of the Platform:

— surname, first name, patronymic;

— email address;

— mobile phone number;

— settlement account data;

— token;

— IP address of the User's device;

Processing method: mixed.

List of actions: collection, recording, systematization, accumulation, storage, clarification (updating, modification), use, transfer (provision, access), anonymization, blocking, destruction.

Processing period: for the duration of the Agreement with the Operator.

Method of termination of processing: blocking and deletion within 3 (three) years from the date of termination of the Agreement.

4.2.2. Use of Users' personal data for the purposes of proper functioning of the Platform in accordance with Users' expectations, in particular for the correct identification of Users, provision of technical support, if the result depends on the data provided:

— surname, first name, patronymic;

— login or username;

— account identifier (ID);

— third-party service account data for authorization;

— email address;

— mobile phone number;

— settlement account data;

— source of referral to the Platform (referrer);

— Order parameters (link/URL, quantity, selected service, amount, date/time, session identifiers),

— transaction data (time/date, receipt identifier);

— token;

— HTTP headers;

— IP address of the User's device;

— cookie data;

— data collected by counters;

— data obtained using web beacons;

— information about the User's browser;

— technical characteristics of the device and software;

— technical data on the operation of the Platform, including dates and times of use and access to the Platform;

— addresses of requested pages of the Platform's website;

Processing method: mixed.

List of actions: collection, recording, systematization, accumulation, storage, clarification (updating, modification), use, transfer (provision, access), anonymization, blocking, destruction.

Processing period: for the duration of the Agreement with the Operator.

Method of termination of processing: blocking and deletion within 3 (three) years from the date of termination of the Agreement.

4.2.3. For the purpose: conducting statistical and other studies of the use of the Platform based on anonymized data;

— login or username;

— account identifier (ID);

— third-party service account data for authorization;

— source of referral to the Platform (referrer);

— HTTP headers;

— IP address of the User's device;

— cookie data;

— data collected by counters;

— data obtained using web beacons;

— information about the User's browser;

— technical characteristics of the device and software;

— technical data on the operation of the Platform, including dates and times of use and access to the Platform;

— addresses of requested pages of the Platform's website;

Processing method: automated.

List of actions: collection, recording, systematization, accumulation, storage, clarification (updating, modification), use, transfer (provision, access), anonymization, blocking, destruction.

Processing period: for the duration of the Agreement with the Operator.

Method of termination of processing: blocking and deletion within 3 (three) years from the date of termination of the Agreement.

4.2.4. For the purpose: conducting the affiliate program, marketing programs, various offers, promotions and advertising events related to the Platform;

— surname, first name, patronymic;

— login or username;

— account identifier (ID);

— email address;

— mobile phone number;

— source of referral to the Platform (referrer).

Processing method: mixed.

List of actions: collection, recording, systematization, accumulation, storage, clarification (updating, modification), use, transfer (provision, access), anonymization, blocking, destruction.

Processing period: for the duration of the Agreement with the Operator.

Method of termination of processing: deletion within 3 (three) years from the date of termination of the Agreement or within 30 days of withdrawal of consent.

4.3. In accordance with the policy, the Operator processes personal data of persons belonging to the following categories of personal data subjects:

4.3.1. natural persons (individual entrepreneurs) using the Platform in accordance with the Agreement on its use on their own behalf;

4.3.2. natural persons using the Platform in accordance with the Agreement on its use on behalf of the individual entrepreneur or legal entity they represent.

4.4. The processing of certain categories of personal data of Users using the Platform both on their own behalf and on behalf of the natural or legal person they represent is carried out with the following features:

4.4.1. User's contact information. A number of data is used to identify the User and their authorization on the Platform and on the Operator's website. Email addresses and phone numbers may be used to send messages to Users (for example, about security or messages with important warnings).

4.4.2. Information about the use of the Platform. Such information is processed for the purpose of studying the activity of the Platform and its interaction with the User, in particular, how long it took the Platform to perform a particular operation at the User's request, which functionality is used by Users more often than others. Such information helps the Operator improve the Platform, increase its performance and make it more user-friendly.

4.4.3. Technical characteristics of the User's device, including its IP address and its software. Information such as device type, operating system, IP address, network connection method, etc., may be needed so that the Operator is able to take into account the nuances of the Platform's functioning on various devices, in various networks and ensure its compatibility with third-party software.

4.5. The Operator does not process biometric personal data (information that characterizes the physiological and biological characteristics of a person, on the basis of which their identity can be established).

4.6. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life, except in cases provided for by the legislation of the Russian Federation.

4.7. The processing of personal data permitted by the subject of personal data for dissemination is carried out on the basis of the consent of the subject of personal data for dissemination, subject to the prohibitions and conditions established by the subject of personal data for the processing of personal data.

4.8. If the subject of personal data, during Registration or during the use of the Platform on their own initiative, provides personal data in a larger volume than is provided for by the Platform's functionality, the Operator has the right not to process such personal data. When the Operator processes such personal data, the processing is carried out in accordance with the rules established by this Policy. The consent to the processing of such data from the subject of personal data is deemed to have been obtained by the Operator at the time of providing such data.

4.9. Cross-border transfer of personal data (if any) is carried out in the manner and to the extent provided for by the legislation of the Russian Federation.

5. PROCEDURE AND CONDITIONS FOR THE PROCESSING OF PERSONAL DATA

5.1. The Operator processes the User's personal data using the personal data information system without the use of automation tools in accordance with federal laws or other regulatory legal acts of the Russian Federation that establish requirements for ensuring the security of personal data during their processing and for respecting the rights of personal data subjects. The use, clarification, dissemination, destruction of personal data in relation to the User is carried out with the direct participation of the Operator's employees in accordance with the features approved by Decree of the Government of the Russian Federation No. 687 of September 15, 2008.

5.2. The Operator processes and stores the User's personal data for the period determined in accordance with the Agreement on the use of the Platform.

5.3. The confidentiality of the User's personal data is maintained, except in cases of voluntary provision by the User of information about themselves for public access to an unlimited number of persons.

5.4. The Operator has the right to transfer the User's personal data to third parties using modern methods of connection encryption via the secure HTTPS protocol in the following cases:

5.4.1. there is the User's consent to such actions, expressed in accordance with the terms of the Agreement on the use of the Platform;

5.4.2. the transfer is necessary for the User to use certain functionality of the Platform (for example, for authorization through accounts in social networks) or for the execution of a certain agreement, contract or transaction with the User;

5.4.3. the transfer is necessary for the acceptance and processing of the User's payments, as well as for confirming the fact of payment. In this case, the Operator has the right to transfer the User's personal data and other information necessary for making the payment to payment systems and payment services (including, but not limited to): Cardlink, Heleket, YooMoney. The scope of transferred data is determined by the requirements of the relevant Payment Service and includes only data necessary for conducting and supporting the payment (for example: amount, purpose, payment/order identifier, contact details for sending a receipt/notification, technical transaction data), while the bank card payment details are processed by the payment service in the manner established by such service.

5.4.4. the transfer is necessary for collecting statistics, analytics and improving the operation of the Platform. In this case, the Operator has the right to transfer data on the use of the Platform (including cookie data, IP address, information about the browser/device, actions on pages and other technical data) to analytical systems, including Yandex.Metrica (counter No. 90815712) (YANDEX LLC, Russia, INN: 7736207543), exclusively for the purposes of the Platform's operation, analysis of its use, improvement of quality and stability of operation.

5.4.5. the transfer is necessary to ensure the User's interaction with the Operator through built-in communication tools (online chat/support service), including. In this case, the Operator has the right to transfer the data provided by the User when contacting, as well as technical data of the communication session to the Chaport chat system (Chaport LLC, Russia, INN: 1215207695) exclusively for the purposes of receiving, processing and maintaining User appeals, monitoring the quality of support and ensuring feedback.

5.4.6. the transfer is necessary for the Operator to fulfill obligations for the provision of SMM services, including the execution of Orders placed by the User on the Platform (including via API), as well as ensuring the technical capability of executing such Orders. In this case, the Operator has the right to transfer to external providers of SMM services (co-executors) information in the minimum necessary volume related to the execution of a specific Order (for example: link to the Resource, Order parameters — service type, quantity, additional options, technical identifiers of the Order/status, as well as other data provided for by the Platform's functionality and necessary for the execution of the Order). The transfer is carried out exclusively for the purpose of providing services to the User.

5.4.7. the transfer is necessary for the provision and support of the Platform's technical infrastructure and/or its individual functions. In this case, the Operator has the right to transfer the User's data (in the minimum necessary volume) to the Perfect Panel technical platform exclusively for the purposes of providing functionality, ensuring the operation of services, automating processes, as well as supporting the "My Site" service (child sites), if the User uses such a service.

5.4.8. the transfer is necessary to authorized state bodies, inquiry and investigation bodies, other bodies and organizations in cases and in the manner provided for by the legislation of the Russian Federation — exclusively for the purpose of fulfilling the requirements of the legislation of the Russian Federation and/or executing mandatory requests of such bodies.

5.4.9. the transfer is provided for by the legislation of the Russian Federation or other applicable law within the framework of the procedure established by law.

5.4.10. in the event of the transfer of rights to the Platform, the transfer of personal data to the acquirer is necessary simultaneously with the transfer of all obligations to comply with the terms of the policy in relation to the personal data received by them;

5.4.11. if it is necessary to ensure the possibility of protecting the rights and legitimate interests of the Operator or third parties, when the User violates the policy or the Agreement on the use of the Platform;

5.4.12. in other cases provided for by law.

5.4.13. The transfer of personal data to third parties under subparagraphs 5.4.2–5.4.7 is carried out exclusively for the purposes of using the Platform and providing services to the User, as well as to the extent necessary to achieve these purposes, in compliance with the principles of legality, minimization and confidentiality of personal data.

5.5. The Operator takes the necessary organizational and technical measures to protect the User's personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties. In particular, all processed data is transmitted using modern methods of connection encryption via the secure HTTPS protocol.

5.6. The Operator, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or unauthorized disclosure of the User's personal data.

5.7. The Operator has the right to transfer personal data to inquiry and investigation bodies, other authorized bodies on the grounds provided for by the current legislation of the Russian Federation.

5.8. When collecting personal data, the Operator records, systematizes, accumulates, stores, clarifies (updates, modifies), and extracts the personal data of Users who are citizens of the Russian Federation using databases located on the territory of the Russian Federation.

5.9. The Operator terminates the processing of the User's personal data, the processing of which is carried out with their consent, upon the expiration of the User's consent to their processing or upon withdrawal of the User's consent to the processing of their personal data, as well as in the event of detection of unlawful processing of personal data or liquidation of the Operator.

5.10. The procedure for the Operator's processing of cookie files and metric data is determined in accordance with the Policy for the collection and processing of cookie files and metric data.

7. ACCESS TO PERSONAL DATA

7.1. The right of access to the User's personal data is granted only to the Operator's employees who are authorized by virtue of their job duties to work with the User's personal data on the basis of the list of persons authorized to work with personal data, which is approved by the Operator.

7.2. The list of employees who have gained access to personal data is maintained by the Operator in an up-to-date state.

7.3. Access to the User's personal data by third parties who are not employees of the Operator without the User's consent is prohibited, except in cases established by the legislation of the Russian Federation.

7.4. An Operator employee's access to the User's personal data terminates from the date of termination of the employment relationship or from the date the employee loses the right of access to the User's personal data due to changes in job responsibilities, position or other circumstances in accordance with the procedure established by the Operator. In the event of termination of the employment relationship, all media containing the User's personal data that were at the disposal of the departing Operator employee are transferred to a higher-ranking employee in the manner established by the Operator.

7.5. The right of access to the User's personal data is granted only to the Operator's employees who are authorized by virtue of their job duties to work with the User's personal data on the basis of the list of persons authorized to work with personal data, which is approved by the Operator.

7.6. The list of persons who have gained access to personal data is maintained by the Operator in an up-to-date state.

7.7. Access to the User's personal data by third parties who are not executors or employees of the Operator without the User's consent is prohibited, except in cases established by the legislation of the Russian Federation.

7.8. An Operator's employee's or executor's access to the User's personal data terminates from the date of termination of the employment or other contractual relationship or from the date such person loses the right of access to the User's personal data.

8. UPDATING, CORRECTION, DELETION AND DESTRUCTION OF PERSONAL DATA

8.1. The User may at any time change, update, supplement or delete the personal data provided by them or part thereof using the Platform interface, or by sending a request to the Operator by email: maxpanel@mail.ru with the subject "Updating personal data" or "Withdrawal of consent to the processing of personal data".

8.2. In the event that the Operator independently identifies a fact of incompleteness or inaccuracy of the User's personal data, the Operator takes all possible measures to update the personal data and make appropriate corrections.

8.3. If it is impossible to update incomplete or inaccurate personal data of the User, the Operator takes measures to delete them.

8.4. In the event of detection of unlawfulness of the processing of the User's personal data, their processing by the Operator is terminated, and the personal data is subject to deletion.

8.5. In the event of inoperability of the Platform interface or the absence of a functional capability of the Platform for the User to change, update, supplement or delete personal data, as well as in any other cases, the User has the right to demand in writing from the Operator the clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing.

8.6. The Operator makes the necessary changes to personal data that is incomplete, inaccurate or irrelevant within a period not exceeding seven working days from the date the User provides information confirming that the personal data is incomplete, inaccurate or irrelevant.

8.7. The Operator destroys illegally obtained or unnecessary for the stated purpose of processing personal data of the User within a period not exceeding seven working days from the date the User provides information confirming that such personal data is illegally obtained or is not necessary for the stated purpose of processing.

8.8. The Operator notifies the User of the changes made and measures taken and takes reasonable measures to notify third parties to whom the personal data of this User has been transferred.

8.9. The User's rights to change, update, supplement or delete personal data may be limited in accordance with legal requirements. Such restrictions, in particular, may provide for the Operator's obligation to retain the personal data changed, updated, supplemented or deleted by the User for a certain period established by law and to transfer such personal data in accordance with the established procedure to state bodies.

9. RESPONSES TO USER REQUESTS FOR ACCESS TO PERSONAL DATA

9.1. The User has the right to receive from the Operator information relating to the processing of their personal data, including containing:

9.1.1. confirmation of the fact of processing of personal data by the Operator;

9.1.2. legal grounds and purposes of processing of personal data;

9.1.3. purposes and methods of processing personal data used by the Operator;

9.1.4. name and location of the Operator, information about persons (except for the Operator's employees) who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Operator or on the basis of federal law;

9.1.5. processed personal data relating to the relevant User, the source of their receipt, unless a different procedure for providing such data is provided for by federal law;

9.1.6. terms of processing of personal data, including terms of their storage;

9.1.7. procedure for the User to exercise the rights provided for by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data";

9.1.8. information on the carried out or intended cross-border data transfer;

9.1.9. name or surname, first name, patronymic and address of the person processing personal data on behalf of the operator, if the processing is entrusted or will be entrusted to such a person;

9.1.10. information on the methods of fulfillment by the operator of the obligations established by Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data";

9.1.11. other information provided for by law.

9.2. The Operator provides free of charge the opportunity to familiarize themselves with the processed and stored personal data in the Operator's information system upon the User's request within ten working days from the date of receipt of the User's written request.

9.3. In the event of the Operator's refusal to provide information on the existence of personal data about the User or personal data to the User upon their request or upon receipt of the User's request, the Operator provides a written reasoned response that is the basis for such refusal within a period not exceeding thirty days from the date of the User's request or from the date of receipt of the User's request. This period may be extended, but not more than by five working days, if the Operator sends a reasoned notice to the personal data subject indicating the reasons for extending the period for providing the requested information.

10. INFORMATION ON THE IMPLEMENTED REQUIREMENTS FOR THE PROTECTION OF PERSONAL DATA

10.1. The security of personal data during their processing in the information system is ensured by a personal data protection system that neutralizes current threats determined in accordance with Part 5 of Article 19 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data".

10.2. The personal data protection system used by the Operator includes legal, organizational, technical and other measures to ensure the security of personal data, determined taking into account current threats to the security of personal data and information technologies used in information systems.

10.3. In relation to personal data for which the User's consent to their processing by third parties has been given, the Operator has the right to engage on the basis of an agreement another person ensuring the security of personal data during their processing in the information system.

10.4. When processing personal data in the Operator's information system, the Operator ensures:

10.4.1. carrying out measures aimed at preventing unauthorized access to the User's personal data and/or their transfer to persons who do not have the right of access to such information;

10.4.2. timely detection of facts of unauthorized access to personal data;

10.4.3. prevention of impact on technical means involved in the processing of personal data, as a result of which their functioning may be disrupted;

10.4.4. the possibility of immediate restoration of personal data modified or destroyed as a result of unauthorized access to them;

10.4.5. constant monitoring of ensuring the level of security of personal data.

10.5. For the purposes of complying with the requirements for ensuring security and implementing the personal data security system, the Operator has developed and implemented a private model of threats to the security of the personal data information system.

10.6. The Operator, in accordance with Decree of the Government of the Russian Federation No. 1119 of November 1, 2012 "On Approval of Requirements for the Protection of Personal Data during Their Processing in Personal Data Information Systems", has determined the level of protection of personal data during their processing in the personal data information system belonging to the Operator.

10.7. Based on the results of determining the level of protection of personal data during their processing in the personal data information system without the use of automation tools, the Operator has developed and implemented a set of measures for the protection and security of personal data.

10.8. The Operator uses technical means and software for processing and protecting personal data, and maintains a log of personal data protection means.

10.9. The Operator maintains a log of accounting and storage of removable information media containing personal data.

10.10. The technical means ensuring the functioning of the personal data information system are located in premises owned by the Operator by right of ownership or other proprietary right (lease, gratuitous use, etc.). The technical means ensuring the functioning of the personal data information system of Users who are citizens of the Russian Federation are located on the territory of the Russian Federation.

10.11. All persons authorized to work with personal data, as well as those involved in the operation and technical maintenance of the personal data information system, are familiar with the requirements of the policy, as well as with the Operator's internal documents regulating the procedure for working with personal data.

10.12. The Operator's internal documents establish that employees are obliged to immediately report to the relevant official of the Operator about the loss, damage or shortage of information media containing personal data, as well as about attempts of unauthorized disclosure of personal data, its causes and conditions.

11. FINAL PROVISIONS

11.1. The User's commencement of use of the Platform means their consent to the terms of the policy. In case of disagreement with the terms of the policy, the use of the Platform must be immediately terminated.

11.2. The law of the Russian Federation shall apply to the policy and to the relations between the User and the Operator arising in connection with the application of the policy.

11.3. The Privacy Policy is in constant open access on the Operator's website at the following link: https://mix-smm.ru/en/policy.

11.4. The User has the right to send all suggestions or questions about the policy to the Operator's user support service by sending an electronic message to the email address: maxpanel@mail.ru.

OPERATOR'S DETAILS

Kolganov Pavel Aleksandrovich

(self-employed)

INN: 710402814358

Address: 300028, Russia, Tula Region, Tula, Sedova St. 35b, apt. 54.

Email: maxpanel@mail.ru

1. Cookie Collection Policy

2. PRIVACY POLICY

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