1. General Provisions
This Privacy Policy and Personal Data Processing Policy (hereinafter referred to as the “Policy”) is drafted in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing and protecting personal data of various categories of personal data subjects (hereinafter referred to as “Subjects”), as well as the personal data security measures implemented by the Moscow Law Firm “Loyal Partners” (TIN 9705242439), located at: 119180, Moscow, Bolshaya Polyanka St., 7/10, Bldg. 1, Premise 9/1/3 (hereinafter referred to as the “Operator”).
The Privacy Policy and Personal Data Processing Policy may be amended by the Operator. The new version of the Policy shall enter into force from the moment of its publication in the public domain.
1.1. The Operator considers it its primary goal and condition for carrying out its activities to comply with the rights and freedoms of man and citizen when processing his or her personal data, including the protection of the right to privacy, personal and family secrecy.
1.2. This Policy applies to all information that the Operator may receive about visitors to the website https://loyal.partners/.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing facilities.
2.2. Blocking of personal data — temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a set of graphical and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at the network address https://loyal.partners/.
2.4. Personal Data Information System — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, without using additional information, the belonging of personal data to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation means on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural entity that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://loyal.partners/.
2.9. Personal data permitted by the personal data subject for distribution — personal data, access to which by an unlimited number of persons has been granted by the subject of personal data by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided for by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://loyal.partners/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an unlimited number of persons (transfer of personal data) or allowing an unlimited number of persons to become familiar with personal data, including publicizing personal data in the mass media, placing them in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign natural person, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of physical media of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
receive truthful information and/or documents containing personal data from the personal data subject;
in case of withdrawal by the personal data subject of consent to the processing of personal data, as well as sending a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
provide the personal data subject, upon his request, with information concerning the processing of his personal data;
organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
provide the authorized body for the protection of the rights of personal data subjects with the necessary information upon request of that body within 10 days from the date of receipt of such request;
publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
take legal, organizational, and technical measures to protect personal data from accidental or unauthorized access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
terminate the transfer (distribution, provision, access) of personal data, terminate processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
fulfill other obligations provided for by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
demand from the operator to clarify their personal data, block or destroy them in case the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as take the measures provided by law to protect their rights;
make the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;
withdraw consent to the processing of personal data, as well as send a request to terminate the processing of personal data;
appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or omissions of the Operator during the processing of their personal data;
exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
provide the Operator with truthful data about themselves;
notify the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the consent of the latter, shall bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achieving the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
| Purpose of processing | Providing the User with access to services, information, and/or materials contained on the website |
| Personal data | Surname, first name, patronymic, email address, phone numbers, year, month, day, and place of birth, photographs |
| Legal grounds | Constituent (founding) documents of the Operator |
| Types of personal data processing | Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data. Sending informational emails to the email address. |
7. Conditions of Personal Data Processing
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary for achieving the purposes provided for by an international treaty of the Russian Federation or by law, for exercising the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for exercising the rights and legitimate interests of the operator or third parties, or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data, access to which by an unlimited number of persons has been provided by the personal data subject or at his request (hereinafter — publicly available personal data) is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or in the event that the personal data subject has given consent to the Operator to transfer data to a third party for the execution of obligations under a civil law contract.
8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator’s email address at office@loyal.partners with the subject line “Update of personal data”.
8.4. The term of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different term is provided for by a contract or current legislation.
The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s email address office@loyal.partners with the subject line “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, communication providers, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject agrees to these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. Prohibitions established by the personal data subject on the transfer (except for provision of access), as well as on the processing or conditions of processing (except for receiving access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject or a request to terminate the processing of personal data, as well as the detection of illegal processing of personal data.
9. List of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before starting activities for the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out a cross-border transfer of personal data (such notification is sent separately from the notification of the intention to carry out personal data processing).
10.2. Before submitting the above notification, the Operator is obliged to receive relevant information from the authorities of a foreign state, foreign natural persons, foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email at office@loyal.partners.
12.2. This document will reflect any changes in the Operator’s personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://loyal.partners/privacy-policy.