torrent-client.com

Personal data processing policy

August 24, 2026

General provisions

This Personal Data Processing Policy (the "Policy") defines the procedure and conditions for the processing of personal data carried out by the Limited Liability Company "MAOMBI RU" (the "Operator") in connection with the use of the website https://torrent-client.com/ (the "Site"), as well as the measures taken by the Operator to ensure the security of personal data and the protection of the rights of personal data subjects.

The Policy has been developed in accordance with the Constitution of the Russian Federation, the Civil Code of the Russian Federation, Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (as amended on 24 June 2025) ("Law No. 152-FZ"), Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies and the Protection of Information", Decree of the Government of the Russian Federation No. 1119 of 1 November 2012, Order of the FSTEC of Russia No. 21 of 18 February 2013, the Recommendations of Roskomnadzor of 31 July 2017 and other regulatory legal acts of the Russian Federation in the field of personal data.

The current version of the Policy is permanently available on the Site free of charge. The Policy is subject to amendment and supplementation in the event of the adoption of new regulatory legal acts and special documents governing the processing of personal data.

The Policy applies to all processes of the Operator relating to the processing of the personal data of Users of the Site, including those carried out with the use of automation tools and without the use of such tools.

1. Definitions used

Personal data — any information relating directly or indirectly to a specified or identifiable natural person (the personal data subject).

Personal data operator — a legal entity or natural person that organises and/or carries out the processing of personal data, and that also determines the purposes of the processing of personal data, the composition of the personal data to be processed, and the actions (operations) performed on personal data.

Processing of personal data — any action (operation) or set of actions (operations) performed on personal data with or without the use of automation tools, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion and destruction of personal data.

Automated processing of personal data — the processing of personal data by means of computer technology.

Blocking of personal data — the temporary cessation of the processing of personal data (except where the processing is necessary in order to clarify the personal data).

Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in a personal data information system and/or as a result of which the material carriers of the personal data are destroyed.

Personal data information system — the aggregate of personal data contained in databases together with the information technologies and technical means that ensure their processing.

Cookies — small fragments of data sent by a web server and stored on the user's device, which may contain identifiers making it possible to track the user's sessions and preferences.

User — a natural person visiting the Operator's Site and/or performing actions on it (viewing pages, downloading installation files and other activity).

2. Information about the Operator

  • Full name: Limited Liability Company "MAOMBI RU"
  • Short name: LLC "MAOMBI RU"
  • Taxpayer identification number (INN): 7703428642
  • Registered address: Russia, Moscow
  • Contact email address: support@maombi.com

3. Principles of the processing of personal data

The Operator carries out the processing of personal data on the basis of the following principles:

3.1. The processing of personal data is carried out on a lawful and fair basis.

3.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. The processing of personal data that is incompatible with the purposes of the collection of the personal data is not permitted.

3.3. It is not permitted to combine databases containing personal data the processing of which is carried out for purposes that are incompatible with one another.

3.4. Only such personal data as corresponds to the purposes of its processing is subject to processing.

3.5. The content and volume of the personal data processed correspond to the declared purposes of the processing. Excessiveness of the personal data processed in relation to the declared purposes of the processing is not permitted.

3.6. When personal data is processed, its accuracy, sufficiency and currency in relation to the purposes of the processing are ensured.

3.7. Personal data is stored in a form making it possible to identify the personal data subject for no longer than is required by the purposes of the processing of the personal data. The personal data processed is subject to destruction or anonymisation upon the achievement of the purposes of the processing, or in the event that the need to achieve those purposes ceases to exist, unless otherwise provided by federal law.

3.8. The Operator ensures that the recording, systematisation, accumulation, storage, clarification (updating, modification) and retrieval of the personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation.

4. Purposes of the processing of personal data

The Operator processes the personal data of Users of the Site for the following purposes:

4.1. Ensuring the functioning of the Site on the information and telecommunications network "Internet", and its technical operability, security and availability.

4.2. Providing information services to Users of the Site, and enabling them to review and download the software placed on the Site.

4.3. Conducting web analytics of Site traffic, analysing the behaviour of Users on the Site, and improving its functioning and the user experience.

4.4. Handling Users' enquiries concerning the functioning of the Site.

4.5. The Operator's compliance with the requirements of the legislation of the Russian Federation.

The processing of personal data for purposes other than those specified in this Section is not carried out.

The Operator carries out the processing of personal data where at least one of the following legal grounds is present:

5.1. The consent of the personal data subject to the processing of their personal data (clause 1 of part 1 of Article 6 and Article 9 of Law No. 152-FZ). Consent is expressed by the User by ticking the relevant box in the cookie notice interface on the Site.

5.2. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, including the public offer contract (the Terms of Use) published on the Site (clause 5 of part 1 of Article 6 of Law No. 152-FZ).

5.3. The processing of personal data is necessary in order to exercise the rights and legitimate interests of the Operator or of third parties, provided that this does not infringe the rights and freedoms of the personal data subject (clause 7 of part 1 of Article 6 of Law No. 152-FZ).

The Civil Code of the Russian Federation, the constituent documents of the Operator and the Terms of Use (public offer) published on the Site are also relied upon as legal grounds.

6. Categories of subjects and the volume of personal data processed

6.1. The Operator processes the personal data of the following categories of subjects:

  • Visitors to the Site — natural persons visiting the Site;
  • Persons who have contacted the Operator — natural persons who have sent enquiries to the Operator by email or by other means.

6.2. In respect of Visitors to the Site, the Operator processes the following categories of data:

  • IP address;
  • cookie identifiers and device identifiers;
  • data on the browser and the operating system;
  • technical information about visits to the Site, including the pages visited, the referral source and the time of the visit;
  • data on the User's actions on the Site collected by web analytics systems.

6.3. In respect of persons who have contacted the Operator, the Operator processes the following categories of data:

  • name (where provided by the User);
  • email address or other contact details provided by the User;
  • the content of the enquiry.

6.4. The Operator does not process special categories of personal data (concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, state of health, intimate life, or information about criminal convictions).

6.5. The Operator does not process biometric personal data within the meaning of Article 11 of Law No. 152-FZ.

7. Procedure and conditions for the processing of personal data

7.1. Methods of processing

The processing of personal data by the Operator is carried out by the following methods:

  • automated processing of personal data with transmission over the "Internet" network;
  • non-automated processing of personal data (where necessary);
  • mixed processing of personal data.

The Operator does not take decisions that give rise to legal consequences in respect of personal data subjects or that otherwise affect their rights and legitimate interests solely on the basis of the automated processing of personal data.

7.2. Actions performed on personal data

The list of actions performed by the Operator on personal data:

collection, recording, systematisation, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion, destruction.

The Operator does not disseminate the personal data of Users of the Site (does not disclose it to an indefinite range of persons).

7.3. Sources of personal data

The Operator obtains personal data:

  • directly from personal data subjects — when they send enquiries to the Operator;
  • automatically — by means of the technical facilities of the Site upon a visit to it (IP address, cookie identifiers, technical data on the browser and device, web analytics data).

7.4. Periods of processing and storage of personal data

The periods of processing and storage of personal data are determined on the basis of:

  • the period of validity of the personal data subject's consent;
  • the period of validity of the Terms of Use (public offer);
  • the periods established by the legislation of the Russian Federation.

Upon the achievement of the purposes of the processing, or upon the occurrence of other lawful grounds, personal data is subject to destruction or anonymisation.

7.5. Localisation of databases

In accordance with part 5 of Article 18 of Law No. 152-FZ, the recording, systematisation, accumulation, storage, clarification (updating, modification) and retrieval of the personal data of citizens of the Russian Federation are carried out by the Operator using databases located within the territory of the Russian Federation.

7.6. Transfer of personal data to third parties

The Operator is entitled to transfer personal data to third parties in the following cases:

7.6.1. With the consent of the personal data subject.

7.6.2. To persons carrying out the processing of personal data on the Operator's instructions on the basis of a concluded contract meeting the requirements of part 3 of Article 6 of Law No. 152-FZ. Such persons include, in particular:

  • the hosting provider on whose servers the Operator's Site is hosted;
  • the provider of the email services used by the Operator for communication with Users;
  • other persons providing the Operator with services relating to the functioning of the Site.

7.6.3. To authorised state authorities of the Russian Federation — in the cases, in the manner and to the extent established by the legislation of the Russian Federation.

7.7. Cross-border transfer of personal data

The Operator does not carry out the cross-border transfer of the personal data of Users of the Site.

8. Use of cookies on the Site

8.1. The Site uses cookies for the following purposes:

  • ensuring the functioning of the Site (technically necessary cookies);
  • conducting web analytics of Site traffic.

8.2. The cookies used on the Site are divided into the following categories:

  • Technically necessary cookies — ensure the basic functioning of the Site. Without them, the correct operation of the Site is impossible.
  • Analytical cookies — used by the Yandex.Metrica system to collect anonymised traffic statistics. The data is processed by a Russian operator (LLC "Yandex").

8.3. Analytical cookies are loaded solely after the corresponding consent of the User has been obtained, expressed through the cookie notice interface on the Site.

8.4. The User is able at any time to withdraw their consent to the use of analytical cookies through their browser settings or through the notice interface on the Site.

9. Measures to ensure the security of personal data

The Operator takes the necessary legal, organisational and technical measures to protect personal data from unlawful or accidental access to it, and from its destruction, modification, blocking, copying, provision or dissemination, as well as from other unlawful actions in respect of personal data.

Such measures include, in particular:

9.1. Organisational measures:

  • the appointment of a person responsible for the organisation of the processing of personal data;
  • the issuance of local acts governing the processing and protection of personal data;
  • familiarising the Operator's employees who process personal data with the provisions of the legislation of the Russian Federation on personal data;
  • exercising internal control over the compliance of the processing of personal data with the requirements of Law No. 152-FZ;
  • identifying threats to the security of personal data during its processing in personal data information systems;
  • establishing rules of access to personal data.

9.2. Technical measures:

  • the use of software and hardware tools for ensuring the security of personal data;
  • the use of encryption (cryptographic) tools and secure connections (TLS) during the transmission of data;
  • ensuring protection against unauthorised access to the carriers of personal data;
  • ensuring the restoration of personal data modified or destroyed as a result of unauthorised access to it;
  • ensuring the established level of protection of personal data in the Operator's personal data information systems in accordance with the requirements of Decree of the Government of the Russian Federation No. 1119 of 1 November 2012.

9.3. Physical measures:

  • preventing the uncontrolled entry or presence of unauthorised persons in premises where work with personal data is carried out;
  • ensuring the safekeeping of the carriers of personal data and of the information protection tools.

10. Rights of personal data subjects

The personal data subject has the right:

10.1. To receive information concerning the processing of their personal data, including information containing:

  • confirmation of the fact of the processing of personal data by the Operator;
  • the legal grounds for and the purposes of the processing of personal data;
  • the purposes and the methods of the processing of personal data applied by the Operator;
  • the name and location of the Operator, and information about the persons who have access to the personal data or to whom the personal data may be disclosed on the basis of a contract with the Operator or on the basis of federal law;
  • the personal data being processed that relates to the relevant subject, and the source from which it was obtained;
  • the periods of the processing of personal data, including the periods of its storage;
  • the procedure for the exercise by the personal data subject of the rights provided for by Law No. 152-FZ;
  • other information provided for by Law No. 152-FZ.

10.2. To require the Operator to clarify, block or destroy their personal data where the personal data is incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the declared purpose of the processing.

10.3. To withdraw their consent to the processing of personal data at any time.

10.4. To require the cessation of unlawful actions of the Operator in respect of their personal data.

10.5. To appeal against the actions or omissions of the Operator to the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or through the courts.

10.6. To the protection of their rights and legitimate interests, including compensation for losses and/or compensation for moral harm through the courts.

11. Procedure for responding to requests from personal data subjects

11.1. Personal data subjects are entitled to send the Operator requests and enquiries on matters relating to the processing of their personal data by email to the address: support@maombi.com.

11.2. A request from a personal data subject must contain information confirming the personal data subject's participation in a relationship with the Operator, or information otherwise confirming the fact that their personal data is processed by the Operator.

11.3. The Operator considers requests from personal data subjects within 10 (ten) business days of the receipt of the request. Where additional time or additional information is required in order to provide a response, the Operator shall notify the personal data subject accordingly.

11.4. Withdrawal of consent to the processing of personal data is carried out by the subject by one of the following means:

  • by changing their preferences in the cookie notice interface on the Site;
  • through their browser settings (deletion of cookies);
  • by sending the Operator a written application to the email address support@maombi.com.

Upon receipt of an application for the withdrawal of consent, the Operator shall cease the processing of the subject's personal data within a period not exceeding 30 (thirty) days of the receipt of the application, except in cases where the retention of certain information is mandatory by virtue of the requirements of the legislation of the Russian Federation.

11.5. Upon receipt of information about the unlawful processing of personal data, the Operator is obliged to block the unlawfully processed personal data relating to the personal data subject from the moment of such an approach or of the receipt of the said request, for the period of the verification.

12. Liability

12.1. The Operator is liable for breaches of the requirements of Law No. 152-FZ in accordance with the legislation of the Russian Federation.

12.2. Persons guilty of breaching the requirements of Law No. 152-FZ and of this Policy shall bear the liability provided for by the legislation of the Russian Federation.

13. Final provisions

13.1. This Policy enters into force from the moment of its approval by an authorised person of the Operator and remains in force indefinitely until it is replaced by a new version.

13.2. The current version of the Policy is permanently available to Users of the Site at the address: https://torrent-client.com/en/pages/privacy-policy/.

13.3. The Operator is entitled to make amendments to this Policy. The new version of the Policy enters into force from the moment of its publication on the Site, unless otherwise provided by the new version.

13.4. The holding by a court that individual provisions of this Policy are invalid shall not entail the invalidity of its remaining provisions.

13.5. On matters not governed by this Policy, the Operator and personal data subjects shall be guided by the provisions of the legislation of the Russian Federation in the field of personal data.