Personal Data Processing Policy

Version dated 11 June 2026 · Modeller service operator

01. General Provisions

This Policy defines how the operator of the Modeller service (the "Operator"), which operates the automated ML model-building platform Modeller (modeller.tech, the "Platform"), processes and protects personal data.

The Policy is prepared in accordance with Russian Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and other applicable regulations. By using the Platform you confirm that you have read this Policy.

The Operator does not verify the accuracy of personal data provided and assumes that the data subject provides accurate data and keeps it up to date.

02. Key Definitions

Personal data

any information relating to a directly or indirectly identified individual (the data subject).

Processing

any operation with personal data: collection, recording, storage, use, transfer, deletion, etc.

Operator

The operator of the Modeller service, which organizes and carries out the processing of personal data.

Subject / User

the individual whose personal data is processed (a site visitor or a registered user).

03. Categories of Data Processed

Account data

email address and password (stored solely as a cryptographic hash).

Technical data

IP address, cookies, device and browser details, activity logs on the Platform.

Uploaded data

datasets and data from integrations (e.g., CRM) you upload to build models. These may contain personal data of third parties — the User is responsible for the lawfulness of their processing.

Support data

information you provide when contacting support or via the contact form.

04. Purposes of Processing

Registration & authentication

creating an account and granting access to the Platform.

Service provision

operation of the Platform, building, validating and deploying ML models at your request.

Service communications

sending service (transactional) notifications and responding to requests.

Contract performance

performing the User Agreement (public offer).

Marketing

sending informational and advertising messages — only with your separate consent.

Legal compliance

meeting the requirements of Russian law.

05. Legal Basis and Consent

Processing is carried out on the basis of the subject's consent (cl. 1 part 1 art. 6 of 152-FZ), the necessity to perform a contract (cl. 5 part 1 art. 6), and to fulfil the Operator's statutory obligations.

Consent to personal data processing is provided as a separate document at registration. Consent to receive marketing messages is provided separately and is voluntary.

06. Storage and Data Localization

Collection, recording, systematization, accumulation and storage of personal data of citizens of the Russian Federation are carried out using databases located on servers within the territory of the Russian Federation (part 5 art. 18 of 152-FZ).

Personal data is stored no longer than required by the purposes of processing or until consent is withdrawn. Uploaded datasets are processed for the duration of service provision and deleted once the purpose is achieved or at the User's request.

07. Transfer to Third Parties

The Operator does not sell or transfer personal data to third parties for advertising purposes.

Transfer is possible to contractors (subprocessors) acting on the Operator's instructions and ensuring confidentiality, as well as in cases provided by law (upon request of authorized bodies). Cross-border transfer is performed only in compliance with art. 12 of 152-FZ.

08. Cookies

The Platform uses technical (necessary) cookies for session management and authentication, and may use analytics cookies. Details are in the Cookie Policy. You can manage cookies via the consent banner and your browser settings.

09. Rights of the Data Subject

Access

obtain information about the processing of your personal data.

Rectification

require correction of inaccurate or incomplete data.

Deletion & blocking

require deletion or blocking of data in case of unlawful processing.

Withdrawal of consent

withdraw consent to processing at any time.

Complaint

appeal the Operator's actions to Roskomnadzor or in court.

To exercise your rights, send a request to contact@modeller.tech. The Operator responds within the timeframes set by 152-FZ.

10. Protection Measures

The Operator takes the necessary legal, organizational and technical measures to protect personal data from unlawful access, destruction, alteration and disclosure (art. 18.1, 19 of 152-FZ): encryption in transit (TLS), password hashing, access control, logging and monitoring.

11. Changes to the Policy

The Operator may amend this Policy. The current version is published on the Platform. Continued use of the Platform after changes are published constitutes acceptance of the updated version.

12. Operator Details and Contacts

Operator: the operator of the Modeller service (modeller.tech)

Full operator details (legal name, OGRN, INN, registered address) are available upon request.

Email for requests: contact@modeller.tech