Personal Data Processing Policy
1. Who processes the data
The personal data operator is the individual Roman Gennadyevich Nadyrov, taxpayer ID (INN) 723018570200, who applies the special tax regime "Professional Income Tax" (self-employed) (hereinafter, the "Operator", "we").
Contact for personal data questions: info@mamaytrading.com.
This policy is drawn up under Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" and is published openly (Part 2 of Article 18.1 of the law).
2. What data we receive and why
| Source | What data | Why |
|---|---|---|
| Early access request | name (how to address you), email or Telegram username, the chosen plan, who you are (trader, investor, etc.), exchanges and interests, the site page | to reply to the request, provide the program build and key, agree on cooperation |
| Support chat on the site and in the MAMAY program | name and contact — if you provide them; message text and attached screenshots; the program copy number (M-XXXXXX), subscription plan; if you tick the box — program version, DEMO/REAL mode, system and the program's latest errors | to answer your question and solve the problem, to improve the program and ready answers |
| Emails to @mamaytrading.com mailboxes | sender's email address and name, subject and text of the email | to reply to the email |
| MAMAY Telegram bot | chat ID, Telegram name and username, message text | to reply in support; to send the program's signals if you connected them yourself with your subscription key |
| Visiting the site | a depersonalized counter: page, referral source, device and browser type, time on page. The IP address is not stored: together with the browser and the date it is used to compute a fingerprint that changes every day and does not allow identifying a person | to understand which sections of the site are useful and where visitors come from |
We do not ask for or receive exchange keys, passwords, bank card details, passport data, or special and biometric categories of personal data. Exchange keys and trades stay on your computer in the MAMAY program and are not transferred to us.
3. Legal grounds for processing
- your consent to the processing of personal data — you give it separately, by ticking a box when submitting a request or the first chat message (clause 1, Part 1, Article 6 of the law); the consent text is here;
- performance of a contract to which you are a party, or actions at your request before it is concluded (clause 5, Part 1, Article 6 of the law) — when you use the program and the subscription.
4. What we do with the data
Collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer (provision, access) in the cases listed in section 5, depersonalization, blocking, deletion and destruction. Processing is mixed: automated and with the involvement of the Operator's staff who answer inquiries.
We do not make decisions that have legal consequences for you based solely on automated processing.
5. Who else gets access
- Hosting provider in Russia (Timeweb): the server for the site, chat and database is located in Moscow. Recording, storage and updating of the personal data of Russian citizens are carried out using databases located in the Russian Federation (Part 5 of Article 18 of the law).
- IONOS email service (Germany): it runs the @mamaytrading.com mailboxes — the emails you send us and our replies. This is a cross-border transfer; Germany is a party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data. The Operator notifies Roskomnadzor of the cross-border transfer (Article 12 of the law).
- Telegram — if you write to the MAMAY bot yourself: messages pass through the Telegram service under its rules.
We do not sell personal data and do not share it for advertising.
6. How long we keep it
- requests, support conversations and emails — until the purpose is achieved and no longer than 3 years from your last inquiry, unless you withdraw your consent earlier;
- depersonalized visit statistics — no longer than 2 years;
- once the purpose is achieved or consent is withdrawn, the data is destroyed within 30 days, unless the law requires it to be kept.
7. Your rights
At any time you can:
- find out what data of yours we have and how we process it;
- demand that data be clarified, blocked or deleted if it is incomplete, outdated or processed unlawfully;
- withdraw your consent to processing;
- appeal our actions to Roskomnadzor or in court.
Write to info@mamaytrading.com from the email or chat you used to contact us. We will reply within 10 business days (Articles 14 and 20 of the law).
8. How we protect data
- only the Operator's staff who answer requests and conversations have access to them — with a password and a second factor;
- connections to the site, chat and server are encrypted (HTTPS);
- mailbox passwords and keys are stored only on the server, not in code or logs;
- a support chat conversation opens only from the browser or program copy where it was started.
9. Cookies and data in the browser
The site uses no cookies, third-party analytics or ad systems. Your browser memory (localStorage and sessionStorage) holds only technical markers: the visit number for the depersonalized counter, the first-visit marker, the chosen color theme and lesson level, and the secret of your support chat conversation — so the support reply can be found when you come back. You can delete them in your browser settings ("Clear site data").
Fonts and all site files are loaded from our server; the browser does not contact third-party services when you open the site.
10. Changes to the policy
We may update the policy; a new version takes effect from the date it is published on this page. The version date is shown at the top.