Privacy Policy for Users

In short, "CarModApps" LLC does not collect any information about its users other than what is necessary for the correct operation of the service.


We use your car's VIN to identify the device on which our Software is running.


We do not ask you to provide your full name or phone number. An email address is required for the automated payment systems to work; we do not use it in any other way.

Privacy Policy for Users
1. General Provisions

1.1. This Privacy Policy (hereinafter - the "Policy") is an integral part of the User Agreement for the CarModApps service and governs the relationship between LLC "CarModApps" (OGRN [Primary State Registration Number], Russian Federation, St. Petersburg, Serebristy boulevard, bldg. 17, k.1, lit.A, room 26-N, office 2), hereinafter referred to as the "Company," which is the rights holder of the CarModApps service (hereinafter - "CarModApps," "Service"), available on the Internet at the website https://carmodapps.com (hereinafter - the "Site"), as well as on the on-board automotive telematics system, and you (a natural person, user of the Internet), hereinafter the "User," regarding the processing of information about the User, including their personal data, in the course of such person's use of the Service (hereinafter - "Information"). This Policy is posted on the Site at https://carmodapps.com

1.2. The relations associated with the processing of information, including, but not limited to, the collection, use, storage, distribution, and protection of information about Users of the Service, are governed by this Policy and other rules posted within the Service, as well as by the current legislation of the Russian Federation. Before starting to use the Company's Service, the User is obliged to familiarize themselves with this Policy, as well as with all applicable rules.

1.3. Upon registration, each access and/or actual use of the Service, the User agrees to the terms of this Policy, as well as to the terms of the agreements and rules of the Service that are posted on the pages (in the sections) of the Service, in the versions that were in effect at the time of the actual use of the Service.

1.4. By using the Service and its functionalities, the User expresses their consent to the terms of this Policy. In case of the User's disagreement with the terms of this Policy, the use of the Service must be immediately terminated.

2. Composition of Information

2.1. The table below details the Information that the Company collects and processes when the User uses the Service, the reasons, purposes of processing the Information, and the legal grounds:


Collected Information

Purpose of Processing

Account Data, namely:

1) Data about the User provided by the User to create an account during registration in the Service, including: first name, last name, mobile phone number, email address, vehicle identification number (VIN). During registration, the User is assigned an internal ID number that identifies the User in the Service.

2) Data additionally provided by the User in the course of using the Service, including a masked bank card number.

To perform the agreement with the User for the provision of the Service's functionality, namely, for the management and administration of the Service, including providing the User with access to the Service and its functionality, as well as carrying out verification. The Company uses the data to fulfill the terms of the User Agreement, in particular, its obligations to Users when they use the Service (for example, in cases where the User needs to go through the authorization procedure in the Service). To perform the agreement with the User for the provision of the Service's functionality, namely the Company uses this data to verify their account and prevent abuse and violation of the User's rights or the rights of others. For example, the Company may use this information to confirm the ownership of the account to the User if they lose their credentials and want to access their account. The Company has the right, but is not obliged, to take additional verification measures that the Company deems reasonable to verify the User's account. The identification of the on-board car system is used for the purpose of tariffing the Service's Services. To perform the agreement with the User for the provision of the Service's functionality, namely: to inform the User about the fact and method of their payment for the Developer's Services on the Service.

Other Data, namely:

3) Data that becomes available to the Company during the User's use of the Service: device data (type, name, model, etc.), IP address, information about the User's browser (including interface language, screen dimensions, etc.), time zone, geolocation, system language, Service version, type of internet connection, name of the mobile operator, version and identifier of applications installed on the device and data on their use (login, time of use).

4) information automatically received when accessing the Service using cookies.

5) information about the User's activity while using the Service, including clicks and transitions within the Service's interface.

To perform the agreement with the User for the provision of the Service's functionality, namely, for internal control and audit of the service's performance under various external conditions, to improve the content and continuity of the Service's functioning, for the management and administration of the Service, preventing failures and errors in the Service's operation.

To notify the User of changes in the Service and to personalize the use of the Service, as well as to display relevant advertising, analyze and optimize advertising campaigns.


2.2. For the purpose of fulfilling obligations to provide the functional capabilities of the Service, the User gives the Company consent to use the phone number or other identifier of the User to send the User service messages using the Company's notification tools (push notifications), including with the involvement of services and applications of the Company's partners or using other services and applications belonging to the Company. In this case, the Company's own SDK is used, and the User's data is not transferred to the Company's partners.

2.3. By registering and/or authorizing in the Service, the User confirms their acquaintance with this Privacy Policy, which is available at the link https://carmodapps.com. The collection of personal data, as well as other information that does not relate to personal data, is carried out in the Service during registration and/or authorization by the User filling out a registration form or by other available means, as well as later when the User edits previously provided information or adds personal data on their own initiative (if applicable) using the Service's functionality, and also automatically during the operation of the on-board telematics system.

2.4. The Company does not verify the Account Data provided by the User and cannot judge its accuracy, nor whether the User has sufficient legal capacity to provide the Account Data. Nevertheless, the Company assumes that the User provides reliable and sufficient Account Data and updates it in a timely manner. By registering on the Service, the User confirms that they have reached the permissible age for using the Service in accordance with applicable law.

2.6. The Company provides developers with the technical ability to place their Products on CarModApps for use by Users. Depending on the specific Product, the Developer may need to process the User's Account and/or Other Data to provide the User with the ability to use the Product, in connection with which the User, by launching and/or using the Product, transfers the data necessary for using the Product to the Developer through CarModApps. In this case, the person who collects, determines the purposes of processing the User's Account and/or Other Data, the composition of the User's Account and/or Other Data to be transferred, and the actions (operations) performed with the User's Account and/or Other Data (processing), is the Developer of the Product.

2.7. The User agrees to the transfer of their Account and/or Other Data to third parties if such processing is necessary for the User to conclude a contract with a third party to which the User will be a party.

3. Principles, Methods, and Conditions for Processing Information (Personal Data)

3.1. The processing of Information about Users is carried out by the Company in accordance with the following principles:

3.1.1. legality of the purposes and methods of Information processing;

3.1.2. good faith of the Company;

3.1.3. conformity of the purposes of Information processing with the purposes predetermined and declared at the time of its collection, as well as with the powers of the Company;

3.1.4. conformity of the volume and nature of the processed Information, and the methods of its processing, with the purposes of Information processing;

3.1.5. inadmissibility of combining databases containing User Information created for incompatible purposes.

3.2. Information is processed by the Company by methods including: collection, recording, systematization, accumulation, storage, clarification (updating, modification), comparison, extraction, use, blocking, deletion/destruction of data for the purposes specified in para. 2.1 of this Policy.

3.2.1. The collection of Information about the User is carried out in the Service during registration and/or authorization using the Service, as well as later when the User edits previously provided information or adds Account Data on their own initiative (if applicable) using the Service's tools, and also automatically during the operation of the on-board telematics system.

3.2.2. Information about the User is stored on the territory of the Russian Federation, exclusively on electronic media and is processed using automated systems, except in cases where non-automated processing of personal data is necessary in connection with the fulfillment of legal requirements. The Company may transfer Information about Users (including cross-border transfer to the territory of foreign states that provide adequate protection of the rights of personal data subjects), including their personal data, to the Company's contractors who are engaged by the Company to provide services for the use of the Service. The provision of this information to the Company's contractors is possible provided that the transfer of this information is necessary to ensure the functioning of the Service and to provide the User with access to its use, and also provided that such contractors have undertaken obligations to ensure the confidentiality of the information received. The Company will retain Information about Users for as long as it is necessary to fulfill the purposes for which this data was collected, depending on the legal grounds for processing, as well as on additional legal/regulatory requirements that establish the need to store information for a certain period of time.

3.2.3. Users' Account and Other Data are not transferred to any third parties, except in cases expressly provided for by this Policy, other applicable rules of the Service, and applicable legislation. The Company may transfer Users' Account and Other Data to third parties, in compliance with the purposes and with the grounds specified in this Policy. Such third parties may include:
  • persons who participate in the provision of services related to the placement and display of information to Users (including offers relevant to the Users' interests) about the Company's services and products in programs, products or services that belong to or are controlled by such persons (for example, owners of sites and applications, advertising networks and other persons, etc.);
  • persons who have legitimate grounds to process Account and Other Data, for example, if the transfer of Account and Other Data to such persons is carried out with the User's consent, including if the Account and Other Data are necessary to provide the User with the relevant service or to perform a specific agreement or contract concluded with the User, in particular, mobile operators and/or technological partners acting between the Company and mobile operators;
  • third parties to whom rights or obligations have been assigned, or novation has occurred under the relevant agreement;
  • any state or local government body to which the Company is obliged to provide information in accordance with applicable law upon a relevant request.

3.2.4. Taking the foregoing into account, and also considering the Company's compliance with the processing purposes specified in para. 2.1. of this Policy, the User agrees to and instructs the Company to perform the following actions:
  • processing, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), comparison, extraction, use, blocking, deletion/destruction of the User's Account and Other Data;
  • transfer to partners and affiliated persons of Account and Other Data, and their processing by partners and affiliated persons, on the instruction of the Company (in the ways specified in this Policy), as well as joint processing by partners and affiliated persons of Account and Other Data with data available to partners and affiliated persons;
  • collection (receipt) from partners and/or affiliated persons of the results of processing Account and Other Data together with data at the disposal of partners and affiliated persons, including in the form of integer and/or text values and identifiers.

3.2.5. Given the nature and functional features of the Service, the Company may facilitate market research activities for goods and services, including assessing supply and demand, promoting goods, and analyzing the effectiveness of information, advertising, and marketing campaigns by forming anonymized analytical information based on data from the use of the Service.

3.2.6. In a number of cases, certain functional capabilities of the Service may be provided not by the Company, but by third parties who act independently of the Company and do not act on behalf of or on the instruction of the Company. In this case, Users are obliged to independently familiarize themselves with the rules for the provision of services and the information/personal data protection policy of such third parties before starting to use the relevant functional capabilities of the Service.

3.2.7. In cases provided for by this Policy, the Company may carry out a cross-border transfer of Information to the minimum extent necessary for the purposes specified in this Policy, to third parties.

3.2.8. The extraction and use of Users' Account and Other Data, including for commercial purposes, is not permitted without the Company's permission.

3.3. Processing of cookies

3.3.1. Cookies are small pieces of data that websites request from the browser used on the User's computer or mobile device. Cookies are stored locally on the computer or mobile device of the Internet user. The Company collects and processes cookies in relation to Users visiting the Company's Service.
3.3.2. The Company's Service uses the following types of cookies:
  • strictly necessary cookies / technical cookies: these cookies are necessary for the site to work and to provide the User with the Service's functionality; among other things, they allow the Company to identify the User's hardware and software, including the browser type;
  • statistical / analytical cookies: these cookies allow for the recognition of Users, counting their number, and collecting information, such as the operations performed on the Service, including information about visited web pages and the content that the User receives;
  • technical cookies: these cookies collect information about how Users interact with the Service, which allows for identifying errors and testing new functions to improve the performance of the Service;
  • functional cookies: these cookies allow for the provision of certain functions to facilitate the use of sites, for example, by saving preferences (such as language and location);
  • cite_start tracking files / advertising cookies: these cookies collect information about traffic sources, pages visited, and advertisements displayed to the User. They allow for the display of advertising that may be of interest to the User, based on the analysis of information collected about the User. They are also used for statistical and research purposes.

3.3.3. Cookies are processed by the Company exclusively for the purpose specified in paragraph 2.1. of this Policy, on the terms and in the manner determined by this Policy. In particular, based on the data obtained with the help of cookies, the Company develops the most useful functionality for the Service available to the User, conducts statistical research, corrects errors in the Services and tests new functions to improve the performance of the Service, personalizes it and shows the most relevant information to the User.

3.3.4. The use of information outside the Service, collected with the help of cookies, for advertising purposes, if any, may be the subject of separate user agreements available on the websites of the Company or third parties. The Company and/or third parties may also provide the User with the opportunity to opt-out of advertising personalization, which may be subject to the legislation and rules applicable to such products and offers.

3.3.5. The User may refuse to have cookies processed in their browser settings. In this case, the Company's Service will only use those cookies that are strictly necessary for the functioning of the Service and the provision of its functionalities, or will refuse to provide the service to the User if it is technically impossible to provide it without the use of cookies.

3.4. Processing of data on the User's device.

3.4.1. For the purpose of personalizing the Service and showing the User the most relevant content that may be of interest to them, as well as to improve the quality of recommendations, the Company (with the prior consent of the User, obtained in the manner specified in para. 3.4.3 of this Policy) uses information obtained on the basis of the User's search queries, views, downloads, updates on the Service, as well as on the basis of data on the use of applications stored on the User's device (for example: data on which applications are used (opened) by the User more often, the time of use of the application, which applications the User installs and deletes).

3.4.2. To improve the quality of recommendations from the Service, the Company also uses aggregated information about which applications a User who has consented to the transfer of analytics data to the Service and the collection of aggregated information about application ratings opens, installs, and deletes.

3.5. Upon reaching the purposes of Information processing, the Company ceases data processing in one of the ways provided for by the current applicable legislation.

4. User Rights

4.1. Users have the right to:

4.1.1. receive free access to information about themselves by viewing the User's Account in the Service;

4.1.2. independently make changes and corrections to information about themselves by editing the information in the User's Account, provided that such changes and corrections contain current and reliable information;

4.1.3. delete information about themselves by editing the information in the Account of the relevant Service (if applicable); however, the deletion by the User of certain information about themselves from the User's Account in the Service may lead to the inability to provide the User with access to that Service;

4.1.4. demand from the Company the clarification of information about the User, its blocking or destruction if such information is incomplete, outdated, unreliable, unreasonably obtained or is not necessary for the stated purpose of processing and if the functionality of the Service does not allow the User to delete such information independently;

4.1.5. upon request, receive from the Company information concerning the processing of information about the User;

4.1.6. refuse the processing of personal data by sending the Company a corresponding request in the manner provided for in section 6 of this Policy.

5. Information Protection Measures

5.1. The Company takes technical and organizational-legal measures to ensure the protection of information about Users from unauthorized or accidental access to them, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions.

5.2. Technical security measures are implemented by the Company taking into account the requirements of applicable legislation, the current state of technology, the nature of the information being processed, and the risks associated with its processing. Information is processed mainly automatically without access to it by employees and/or contractors of the Company. If such access is granted to employees or contractors of the Company, it is only to the extent necessary for such persons to perform their official duties or obligations under a contract with the Company, and such persons are charged with the duty to comply with security requirements when accessing the Information. To protect and ensure data confidentiality, all employees/contractors comply with internal rules and procedures regarding information processing. These persons also comply with all technical and organizational security measures provided for by applicable law and necessary to protect information about Users.

5.3. The User is responsible for the safety of the data used by the User for authorization on the Service. They are not entitled to transfer such information to third parties and are also obliged to take measures to ensure its confidentiality.

6. User Requests

6.1. Information about the data processed by the Company, including the User's personal data, in connection with their use of the Service, is provided to the User or their representative upon request.

6.2. Requests are sent in written form to the address of the Company's location or in another form provided for by the current legislation of the Russian Federation.

6.3. The User has the right to withdraw consent to the processing of their personal data by sending the Company a written statement at the Company's location in accordance with the requirements of the current legislation.

7. Changes and Additions to this Policy

7.1. This Policy may be changed by the Company with notification to the User, including by posting a new version of the amended policy on the website at https://carmodapps.com. Changes to the Policy made by the Company come into force on the day following the day of posting the new version of the Policy on the Site. Continued use of the Service after changes are made to the Policy means the User's acceptance and agreement with such changes.

7.2. The User has the right to refuse to accept the changes and additions to this Policy, which means the User's refusal to use the Service and all rights previously granted to them.

7.3. This Policy is governed by and interpreted in accordance with the legislation of the Russian Federation. Issues not regulated by this Policy are subject to resolution in accordance with the current applicable legislation.

Version of May 28, 2025.