Privacy Policy

Policy Regarding the Processing of Personal Data

1. General Provisions

This Personal Data Processing Policy has been drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the "Personal Data Law") and defines the procedures for processing personal data and the measures taken by ORLOVA ERMOLENKO LLC (hereinafter referred to as the "Operator") to ensure the security of personal data.

1.1. The Operator's primary objective and a fundamental condition for its operations is the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the right to privacy and the confidentiality of personal and family life.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://oe.legal.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — the processing of personal data using computing equipment.

2.2. Blocking of personal data — the temporary cessation of the processing of personal data (except in cases where such processing is necessary for the purpose of updating or correcting personal data).

2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, that are made accessible on the Internet at the network address https://oe.legal.

2.4. Personal data information system — a set of personal data contained in databases, along with the information technologies and technical means used to process such data.

2.5. Anonymization of personal data — actions that render it impossible to determine, without the use of additional information, which specific User or other personal data subject the data belongs to.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed on personal data, whether or not by automated means, including the collection, recording, systematization, accumulation, storage, refinement (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, or destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity, or individual who, either independently or jointly with other persons, organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with such personal data.

2.8. Personal data — any information relating, directly or indirectly, to a specific or identifiable user of the website https://oe.legal.

2.9. Personal data authorized by the data subject for dissemination — personal data to which an unlimited number of persons have been granted access by the data subject through the provision of consent for the processing of personal data authorized by the data subject for dissemination, in accordance with the procedure established by the Law on Personal Data (hereinafter referred to as "personal data authorized for dissemination").

2.10. User — any visitor to the website https://oe.legal.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including the publication of personal data in the mass media, posting it on information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data, making it impossible to subsequently restore the content of such data within an information system for personal data, and/or the destruction of the physical media on which the personal data is stored.

3. Key Rights and Obligations of the Operator

3.1. The Operator has the right to:

• receive accurate information and/or documents containing personal data from the personal data subject;
• in the event that the personal data subject withdraws their consent to the processing of personal data, or submits a request to cease the processing of personal data, the Operator may continue to process such personal data without the subject's consent, provided there are legal grounds for doing so as specified in the Law on Personal Data;
• independently determine the scope and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obligated to:

• provide a data subject, upon their request, with information concerning the processing of their personal data;
• organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
• provide the authorized body for the protection of the rights of data subjects with necessary information, upon that body's request, within 10 days from the date of receipt of such a request;
• publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
• implement legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure, dissemination, or any other unlawful actions in relation to personal data;
• cease the transfer (dissemination, disclosure, provision of access) of personal data, cease processing, and destroy personal data in the manner and in the cases provided for by the Law on Personal Data;
• fulfill other obligations as provided for by the Law on Personal Data.

4. Fundamental Rights and Obligations of Subjects of Personal Data

4.1. Personal data subjects have the right to:

• obtain information regarding the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided to the personal data subject by the Operator in an accessible format and must not contain personal data relating to other personal data subjects, unless there are legal grounds for the disclosure of such personal data. The scope of information and the procedure for obtaining it are established by the Law on Personal Data;
• request that the Operator clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, obtained unlawfully, or are not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;
• stipulate a requirement for prior consent when personal data are processed for the purpose of promoting goods, works, or services on the market;
• withdraw their consent to the processing of personal data, as well as submit a request to cease the processing of their personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or to a court regarding any unlawful actions or omissions by 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 obligated to:

• provide the Operator with accurate information about themselves;
• notify the Operator of any clarifications (updates, changes) to their personal data.

4.3. Individuals who provide the Operator with inaccurate information about themselves, or information about another data subject without the latter's consent, shall be held liable in accordance with the legislation of the Russian Federation.

5. Principles for the Processing of Personal Data

5.1. The processing of personal data shall be carried out on a lawful and fair basis.

5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful objectives. Processing of personal data that is incompatible with the purposes for which the data was collected is not permitted.

5.3. It is not permitted to combine databases containing personal data that are processed for purposes that are incompatible with one another.

5.4. Only personal data that is relevant to the purposes of its processing shall be subject to processing.

5.5. The content and volume of the personal data being processed shall correspond to the stated purposes of processing. The personal data being processed shall not be excessive in relation to the stated purposes for which it is processed.

5.6. During the processing of personal data, the accuracy, sufficiency, and—where necessary—the up-to-date status of the data in relation to the purposes of processing shall be ensured. The operator shall take, or ensure the taking of, necessary measures to delete or rectify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows for the identification of the data subject for no longer than is required by the purposes for which the data is processed, unless a different storage period is established by federal law or by a contract to which the data subject is a party, a beneficiary, or a guarantor. Personal data being processed shall be destroyed or anonymized upon the achievement of the processing objectives or when such objectives are no longer relevant, unless otherwise provided for by federal law.

6. Purposes of Personal Data Processing

7. Conditions for the Processing of Personal Data

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the exercise of the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.

7.3. The processing of personal data is necessary for the administration of justice, the 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. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, or a beneficiary or guarantor under which the subject of personal data is, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.

7.6. The processing of personal data is carried out, access to which by an unlimited circle of persons is provided by the subject of personal data or at their request (hereinafter — publicly available personal data).

7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for the Collection, Storage, Transfer, 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 for the full fulfillment of 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 prevent 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 performance of applicable legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.

8.3. In the event that inaccuracies are identified in the personal data, the User may update them independently by sending the Operator a notification to the Operator's email address oe@oe.legal with the note "Updating of personal data".

8.4. The period of processing of personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or applicable legislation. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification by email to the Operator's email address oe@oe.legal with the note "Withdrawal of consent to the processing of personal data".

8.5. All information that is collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the said documents. The Operator is not responsible for the actions of third parties, including those specified in this clause of service providers.

8.6. The prohibitions established by the subject of personal data on transfer (except for the provision of access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for dissemination, 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, when processing personal data, ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that allows for the identification of the subject of personal data, for no longer than is required by the purposes of processing personal data, if the storage period of personal data is not established by federal law or by a contract to which the subject of personal data is a party, a beneficiary, or a guarantor.

8.9. The condition for the termination of the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or a request to cease the processing of personal data, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Received Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunications networks or without such.

10. Cross-border Transfer of Personal Data

10.1. The Operator, before commencing activities for the cross-border transfer of personal data, is obligated to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of intention to carry out the processing of personal data).

10.2. The Operator, before submitting the above-mentioned notification, is obligated to obtain from the authorities of the foreign state, foreign individuals, foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obligated not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on questions of interest concerning the processing of their personal data by contacting the Operator via email oe@oe.legal.

12.2. This document will reflect any changes to the policy of processing of personal data by the Operator. 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://oe.legal.