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Personal Data Processing Policy

Federal Law No. 152-FZ "On Personal Data" · BFD Attorneys at Law

1. General provisions

1.1. This Personal Data Processing Policy (the "Policy") of the Sverdlovsk Region Attorneys' Bureau "Bezopasnost Finansovoy Deyatelnosti" (Financial Activity Security) (INN 6685199875, OGRN 1226600028357, address: office 8.09, 101 Mamina-Sibiryaka St., Yekaterinburg, 620075, Russia) (the "Operator", "BFD") has been adopted in accordance with Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies and Information Protection", Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" and other applicable regulations on personal data.

1.2. The purpose of this Policy is to protect the rights and freedoms of data subjects when their personal data is processed by the Operator.

1.3. Terms used in this Policy have the meanings assigned to them by Federal Law No. 152-FZ "On Personal Data".

1.4. Key rights of the data subject:

  • by providing personal data, the data subject consents to its processing by the Operator;
  • the data subject may obtain from the Operator information concerning the processing of their personal data;
  • the data subject may require the Operator to rectify, block or destroy personal data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, and may take measures provided by law to protect their rights;
  • if the data subject believes that the Operator processes their personal data in breach of the law or otherwise violates their rights and freedoms, the data subject may lodge a complaint with the competent data protection authority or with a court;
  • the data subject may withdraw consent to the processing of personal data;
  • the data subject is entitled to protection of their rights and legitimate interests, including compensation for damages and/or moral harm through the courts.

1.5. Key obligations of the Operator:

  • upon a written request of the data subject, provide information concerning the processing of their personal data, or issue a lawful refusal, within thirty days of receipt of the request;
  • upon a written demand of the data subject, rectify, block or delete personal data that is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, within thirty days of receipt of the demand;
  • once the purpose of processing has been achieved, immediately cease processing and destroy the relevant personal data within thirty days, unless otherwise provided by a contract or other agreement with the data subject;
  • if the data subject withdraws consent, cease processing and destroy the personal data within thirty days of receipt of the withdrawal, unless otherwise agreed with the data subject;
  • take the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision or dissemination, and against other unlawful actions.

1.6. Rights of the Operator:

  • the Operator collects, uses and protects personal data provided by the data subject when using the Operator's website https://abfd.ru (the "Website") from any device and through any form of communication, as well as personal data voluntarily submitted for publication on the Website, in accordance with this Policy;
  • the Operator may inform the data subject of new publications on the Website; of news, including of a promotional nature; of new Website features; of analytical and informational materials; and of events held by the Operator and other organisations. Communications may be sent by e-mail, SMS/MMS, messaging services, telephone calls and push notifications;
  • the Operator may publish on the Website personal data provided by subjects in the category "persons mentioned and/or depicted in publications on the Website", in accordance with Section 4 of this Policy (in whole or in part).

2. Purposes of collection and processing of personal data

2.1. Personal data is collected and processed by the Operator for the purposes of:

  • registering the data subject on the Website to grant access to certain sections and functions;
  • creating a unique user account on the Website;
  • enabling the data subject to publish materials on the Website;
  • informing the data subject about the Operator's events and enabling participation in them;
  • communicating with the data subject when they contact the Operator;
  • organising the data subject's participation in events and surveys conducted by the Operator;
  • sending the data subject news, analytical and informational materials and/or links to such materials;
  • compiling statistics;
  • fulfilling the Operator's statutory purposes;
  • other purposes with the data subject's consent.

2.2. The Operator collects and processes personal data to perform the duties imposed on it by Federal Law No. 63-FZ of 31 May 2002 "On Advocacy and the Bar in the Russian Federation", including the provision of qualified legal assistance to organisations and individuals.

2.3. Unless otherwise provided by a legal services agreement, the Operator does not take decisions producing legal consequences for the data subject, or otherwise affecting their rights and legitimate interests, on the basis of solely automated processing of personal data.

3. Legal grounds for processing

3.1. The legal grounds for processing personal data are:

  • Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies and Information Protection";
  • Federal Law No. 152-FZ of 27 July 2006 "On Personal Data";
  • Law of the Russian Federation No. 2124-1 of 27 December 1991 "On Mass Media";
  • Federal Law No. 63-FZ of 31 May 2002 "On Advocacy and the Bar in the Russian Federation";
  • Regulation on the specifics of non-automated processing of personal data (approved by Government Resolution No. 687 of 15 September 2008);
  • Government Resolution No. 1119 of 1 November 2012 on personal data protection requirements in information systems;
  • FSTEC Order No. 21 of 18 February 2013 on organisational and technical measures for personal data security;
  • Roskomnadzor Order No. 996 of 5 September 2013 on personal data anonymisation requirements and methods;
  • other regulations of the Russian Federation and regulatory documents of competent state authorities;
  • the Operator's internal regulations;
  • the data subject's consent to processing.

4. Scope and categories of personal data processed; categories of data subjects

4.1. Personal data covered by this Policy is provided by the data subject by completing forms on the Website, by sending messages addressed to the Operator, or otherwise — freely, of their own will and in their own interest.

4.2. Categories of data subjects:

  • Website users;
  • subscribers to publication updates;
  • persons mentioned and/or depicted in publications on the Website.

4.3. Subjects in the category "Website users" provide the following personal information (in whole or in part), not subject to dissemination — subscribers to publication updates:

  • e-mail address*.

* An asterisk marks information that is mandatory.

4.4. Subjects in the category "persons mentioned and/or depicted in publications on the Website" provide the following personal information (in whole or in part):

Public data (subject to dissemination):

  • full name*;
  • date and place of birth;
  • education (institution) and qualifications;
  • family composition;
  • employment history* and length of service;
  • positions in public organisations, academic and educational institutions*;
  • academic degree and title;
  • professional specialisation;
  • awards and other distinctions;
  • where involved in a specific case: procedural status, case number, type of proceedings (criminal, civil, administrative), stage of proceedings, legal qualification of the offence;
  • for attorneys additionally: bar chamber*, law firm/bureau*, bar status (active, suspended, terminated)*, positions in bar self-governance bodies;
  • photographs;
  • video images.

Non-public data (not subject to dissemination):

  • passport details;
  • e-mail address*;
  • telephone number.

* An asterisk marks data that is mandatory.

4.5. The Operator protects data transmitted automatically while the data subject views advertising blocks, including cookies, in accordance with Section 8 of this Policy.

4.6. The Operator collects statistics on visitors' IP addresses. This information is used to compile aggregate data on Website traffic.

4.7. The Operator does not verify the accuracy of personal data provided by the data subject and cannot assess their legal capacity. The Operator assumes that the data subject provides accurate and sufficient data and keeps it up to date.

5. Procedure and conditions of processing

5.1. The Operator collects, records, systematises, accumulates, stores, refines (updates, amends), retrieves, uses, transfers (disseminates, provides, grants access to), anonymises, blocks, deletes and destroys personal data.

5.2. Personal data is processed:

  • without automation;
  • by automated means, with or without transmission over information and telecommunication networks;
  • by mixed means.

5.3. Processing periods are determined with regard to:

  • the stated purposes of processing;
  • the terms of contracts with data subjects and of consents to processing;
  • the periods established by personal data legislation.

5.4. The Operator does not disclose personal data to third parties or disseminate it without the data subject's consent (unless otherwise provided by federal law).

5.5. Processing ceases when its purposes have been achieved, when the consent expires or is withdrawn, or when unlawful processing is identified.

6. Personal data security

6.1. The Operator takes the necessary and sufficient legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision or dissemination, and against other unlawful actions, in accordance with Federal Law No. 152-FZ "On Personal Data" and regulations adopted under it.

6.2. The Operator has adopted internal regulations on personal data security. Employees with access to personal data have been familiarised with this Policy and those regulations.

7. Updating and destruction of personal data; responses to data subjects' requests

7.1. Where personal data is confirmed to be inaccurate or unlawfully processed, it is updated by the Operator and the previous data is no longer processed.

7.2. When the purposes of processing have been achieved, or where the data subject withdraws consent, the personal data is destroyed unless otherwise agreed between the Operator and the data subject.

7.3. The data subject is entitled to information concerning the processing of their personal data. Requests may be sent in writing to: office 8.09, 101 Mamina-Sibiryaka St., Yekaterinburg, 620075, Russia, or by e-mail to office(at)abfd.ru.

7.4. Demands to cease processing, to rectify, block or destroy personal data, and withdrawals of consent, should be sent to office(at)abfd.ru.

8. Cookies and other tracking technologies

8.1. Personal data of Website visitors and users processed for analytical purposes may be transferred to third-party services (including Yandex.Metrica) and to tools of the platform on which the Website is built, by providing it to a defined range of persons or by granting authorised access.

8.2. Third-party services (including Yandex.Metrica) process the following data of Website visitors and users for analytical purposes: gender; age; approximate geographic location; referral sources; search phrases used to reach the Website; bounce rates; time spent on the Website; browsing depth; ad click-through rates; conversion.

8.3. Platform tools process the following data for analytical purposes: IP address; approximate location; device and application data (type, operating system, device or application identifier, browser version, language settings); date and time of device use; cookies and pixels installed on or interacted with through the device; recorded activity (sessions, clicks, feature use, mouse movement and other interactions); third-party cookies used to embed third-party elements such as videos, feedback forms or social media buttons; web beacons (included, among other things, in electronic mailings to determine whether messages were opened and what happened to them subsequently).

9. Links to third-party websites

9.1. The Website may contain links to third-party websites and services not controlled by the Operator. The Operator is not responsible for the security or confidentiality of any information collected by such websites or services.

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