WEBSITE USER PRIVACY POLICY

1. General provisions

1.1 This Website User Privacy Policy (hereinafter — the Policy) is developed in accordance with the requirements of the Federal Law of the Russian Federation «On Personal Data» № 152-FZ of July 27, 2006 (hereinafter — the Law on Personal Data), as well as Russian and international legislation in order to ensure the protection of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrecy. The legal basis for the processing of personal data is a set of regulatory legal acts, in pursuance of which and in accordance with which Semchenko & Partners LLC processes personal data, including:

— Constitution of the Russian Federation;

— Civil Code of the Russian Federation;

— Federal Law of 08.02.1998 N 14-FZ «On Limited Liability Companies»;

— other normative legal acts regulating relations related to the Operator’s activities.

1.2 The Policy applies to the activities of Semchenko & Partners Limited Liability Company located at 7, Lieter A, Akademika Pavlova St., St. Petersburg, 197022, room 396-N (hereinafter referred to as Semchenko & Partners LLC, Operator) when processing personal data provided through the use by personal data subjects of the Semchenko & Partners LLC website at https://semchenko.su, including by sending information to e-mail addresses placed on the website of Semchenko & Partners LLC.

1.3 The Policy applies to all personal data provided by users of the website, which is processed by Semchenko & Partners LLC. The Policy applies to the relations in the field of personal data processing, arisen at the Operator both before and after the approval of this Policy.

1.4 The Policy defines the approach of Semchenko & Partners LLC to the processing and protection of personal data. The Policy is an open and publicly available document. If you have any questions related to the Policy, including suggestions to improve its understanding and navigation, or have any questions about our processing and protection of your personal data, you can send us an e-mail.

1.5 The Policy applies to all information containing personal data that Semchenko & Partners LLC can obtain about the Subject and for which its consent is obtained.

1.6 The Operator has the right to make changes to this Policy without the User’s consent. The changes shall come into effect from the date determined by the Operator. The changes are subject to publication on the Website.

1.7 Basic concepts used in the Policy:

personal data — any information relating to a directly or indirectly defined or identifiable natural person (Subject);
personal data operator (operator) — a state authority, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data;
processing of personal data — any action (operation) or set of actions (operations) with personal data performed with or without the use of automation tools.

The processing of personal data includes, but is not limited to:

collection;
entry;
systematization;
accumulation;
storage;
clarification (update, change);
extraction;
Utilization;
transfer (distribution, provision, access);
depersonalization;
blocking;
deletion;
annihilation.

automated processing of personal data — processing of personal data by means of computer equipment;
dissemination of personal data — actions aimed at disclosure of personal data to an indefinite number of persons;
provision of personal data — actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
blocking of personal data — temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data);
destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed;
depersonalization of personal data — actions, as a result of which it becomes impossible to determine the belonging of personal data to a particular Subject without using additional information;
personal data information system — a set of information technologies and technical means contained in databases of personal data and ensuring their processing;
confidentiality of personal data — the obligation of persons who have access to personal data not to disclose them to third parties and not to disseminate personal data without the Subject’s consent, unless otherwise provided for by federal law;
cross-border transfer of personal data — transfer of personal data to the territory of a foreign country to a foreign authority, a foreign natural person or a foreign legal entity;
site user, Subject — any physical person in accordance with the current legislation of the Russian Federation who has visited the Site;
Cookie files are a piece of data sent by a web server, which are stored in a file on the user’s computer for further identification on the Site;
Website — a website at https://semchenko.su used by Semchenko & Partners LLC to inform about its services; the owner of the website is Semchenko & Partners LLC.

2. Basic rights and obligations of the Operator

The operator shall have the right to:

independently determine the composition and the list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on personal data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on personal data or other federal laws;
to entrust the processing of personal data to other persons with the Subject’s consent, unless otherwise provided for by federal law, on the basis of a contract concluded with that person;
in case the Subject revokes his/her consent to the processing of personal data, Semchenko & Partners LLC has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law.

The operator is obligated to:

organize the processing of personal data in accordance with the requirements of the Personal Data Law;
not to disclose or distribute personal data to third parties without the Subject’s consent, unless otherwise provided for by law;
to take measures aimed at ensuring the fulfillment of obligations stipulated by the legislation on personal data; to take measures to ensure the security of personal data during their processing;
n case of establishing the fact of unlawful or accidental transfer (provision, dissemination, access) of personal data resulting in violation of the rights of the Subjects, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects from the moment of detection of such incident by the Operator, the authorized body for the protection of the personal data subjects or other interested person:
— within 24 hours about the incident that occurred, about the alleged reasons that resulted in the violation of the rights of personal data subjects
to provide necessary information on personal data processing at the subject’s request or upon receipt of the subject’s or his/her representative’s request, as well as the authorized body for the protection of the rights of personal data subjects in accordance with the requirements of the Law on Personal Data;
eliminate violations of legislation committed during the processing of personal data, clarify, block and destroy personal data in cases established by the legislation on personal data;
publish or otherwise provide unrestricted access to the Policy, to the information on the implemented requirements to personal data protection;
to take the necessary legal, organizational and technical measures or ensure their adoption to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data.

3. Collection of personal data of minors

The site is not intended for processing personal data of minors. If you have reason to believe that a child has provided the Operator with his/her personal data, please contact the Operator and inform about it by writing to the e-mail: office@semchenko.su.

4. Subjects, scope, categories and purposes of personal data processing

4.1 A natural person or a representative of a legal entity who has accessed the website of Semchenko & Partners LLC:

The scope and list of personal data that may be processed:

Individuals:

last name, first name, middle name;
contact information: cell phone number, e-mail address;
information provided to enable the provision of legal aid;

Representatives of legal entities:

last name, first name, middle name;
contact information: mobile and/or office phone number, e-mail address;
information provided to enable the provision of legal aid;
information about the position and place of employment.

Purpose of processing:

providing the User of the Site with the opportunity to familiarize with the information posted on the Site and the activities of Semchenko & Partners LLC;
for communication in a way convenient for the User of the Website;
information, advertising, marketing and other purposes aimed at realization and promotion of the Operator’s activities.

4.2 Other persons, including visitors to events organized by Semchenko & Partners LLC, persons receiving Semchenko & Partners LLC newsletter.

The scope and list of personal data that may be processed:

last name, first name, middle name;
contact information: mobile and/or office phone number, e-mail address;
information about the position and place of employment.

Purpose of processing:

information, advertising, marketing purposes aimed at implementation and promotion of the Operator’s activities, including sending information mailings and marketing booklets/offers of legal assistance, invitations to seminars and other events, organization of meetings, attendance and participation in seminars and other events organized and conducted by Semchenko & Partners Ltd.

5. Procedure and conditions of personal data processing

Collection and subsequent processing of personal data by Semchenko & Partners LLC is allowed only after obtaining consent for processing from the Subject or his/her representative, as well as without obtaining such consent in cases stipulated by the legislation of the Russian Federation. Consent is considered to be obtained from the User from the moment of entering the Site, familiarizing with the content of the pop-up window mentioned below, and continuing to be on the Site.

Place a pop-up window on the Site with the following information:

«This site uses cookies to collect anonymized personal data for the purposes of traffic analysis and advertising customization. By staying on the site, you agree to the use of cookies and give your Consent to the processing of personal data. More detailed information can be found in the Privacy Policy of the site users.».

In all cases of processing of personal data of the Subjects Semchenko & Partners LLC is guided by the provisions of the current legislation, Policy and local regulations of Semchenko & Partners LLC.

In order to disseminate personal data, the Operator shall obtain consent to the processing of personal data authorized by the Subject for dissemination, which shall be executed separately from other consents of the Subject to the processing of his/her personal data. The content of the consent to the processing of personal data authorized by the Subject for dissemination shall comply with the requirements established in accordance with Article 9.9 of the Personal Data Law. The Operator is obliged to provide the Subject with an opportunity to determine the list of personal data for each category of personal data specified in the consent to the processing of personal data authorized by the Subject for dissemination. In the consent to the processing of personal data authorized by the Subject for dissemination, the Subject has the right to establish prohibitions on the transfer (except for providing access) of such personal data by the Operator to an unlimited number of persons, as well as prohibitions on processing or conditions of processing (except for access) of such personal data by an unlimited number of persons.

Trans-border transfer of personal data may be carried out by Semchenko & Partners LLC in accordance with the provisions of the current legislation of the Russian Federation after obtaining the written consent of the Subject.

Public authorities of the Russian Federation, ministries and departments may gain access to processed personal data only in cases and in accordance with the procedure established by the legislation of the Russian Federation.

The Operator has the right to entrust the processing of personal data to another person with the Subject’s consent, unless otherwise provided for by federal law, on the basis of a contract concluded with this person. Persons processing personal data on behalf of the Operator shall be obliged to comply with the principles and rules of personal data processing stipulated by the Personal Data Law, as well as to take measures to protect personal data and comply with other rules of personal data processing established by this Policy and the relevant contract.

In accordance with part 5 of Article 18 of the Law on Personal Data, when collecting personal data, including through the information and telecommunications network «Internet», the Operator shall ensure recording, systematization, accumulation, storage, clarification (update, change), extraction of personal data of citizens of the Russian Federation using databases located in the territory of the Russian Federation.

6. Methods and terms of personal data processing

6.1 Semchenko & Partners LLC shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete, destroy personal data.

Semchenko & Partners LLC carries out mixed processing of personal data (with and without the use of means of automation). The information obtained in the course of personal data processing is transmitted via the Operator’s internal network, as well as using the Internet.

The period of personal data processing by Semchenko & Partners LLC may not exceed the period determined by the purposes of personal data processing specified in clause 4 of this Policy.

The condition for termination of personal data processing is also the expiration of the consent or withdrawal of the Subject’s consent to the processing of his/her personal data (if the applicable law does not provide for the Operator’s right to process personal data in the absence of consent), as well as the detection of unlawful processing of personal data.

Personal data shall be stored in a form that allows identification of the Subject for no longer than required for the purposes of personal data processing, except where a different period of personal data storage is established by federal law or a contract to which the Subject is a party, beneficiary or guarantor.

6.2 Cookies and automatic logging.

Cookies are one of the technologies that the Operator uses to automatically collect information and improve the quality of content.

The Site also performs automated collection and processing of anonymized data about users of the Site, including through cookies, using Internet statistics services.

The user of the Site realizes that the equipment and software used by him to visit the Site may have the function of prohibiting operations with cookies (for any site or for certain sites), as well as the deletion of previously received cookies.

The structure of the cookie file, its content and technical parameters are determined by the Site and may be changed without prior notice to the Site User.

Counters placed by the Site may be used to analyze the User’s cookies, to collect and process statistical information on the use of the Site, as well as to ensure the performance of the Site as a whole or their individual functions in particular. Technical parameters of counter operation are determined by the Site and may be changed without prior notice to the Site User.

The Site may also process such personal data as metadata of the Site User (IP address and location data).

7. Ensuring the security of personal data

Semchenko & Partners LLC has taken the following measures necessary and sufficient to ensure fulfillment of the obligations of the personal data controller stipulated by the legislation of the Russian Federation on personal data:

The Operator has appointed a person responsible for organization of personal data processing;
The Operator has appointed a person responsible for ensuring the security of personal data;
Administrators of the information systems of Semchenko & Partners LLC, where personal data are stored, have been appointed as the operator;
The Operator has approved the list of persons authorized to process personal data;
The Operator has approved local acts on the issues of personal data processing, detection and prevention of violations of the Russian Federation legislation in the field of personal data and elimination of such violations;
Personal data processed without the use of automation means are separated from other information, in particular by fixing them on separate material carriers of personal data, in special sections, and stored in specially equipped premises;
Separate storage of personal data and their material carriers, which are processed for different purposes and contain different categories of personal data, is ensured;
Personal data are stored electronically in the information systems of Semchenko & Partners LLC, as well as in archived copies of the databases of these systems, in compliance with the conditions ensuring the safety of personal data and excluding unauthorized access to them;
It is prohibited to transfer personal data via open communication channels and Internet networks without applying the personal data security measures established by Semchenko & Partners LLC;
Internal control over compliance of personal data processing with the Personal Data Law and regulations adopted in accordance with it, personal data protection requirements, this Policy and local acts of Semchenko & Partners LLC is carried out;
Semchenko & Partners LLC employees who process personal data are periodically familiarized with the provisions of the legislation of the Russian Federation on personal data (including requirements for personal data protection) and local acts of Semchenko & Partners LLC on personal data processing;
The rules of access to personal data processed in the information systems of personal data of Semchenko and Partners LLC are established, as well as registration and record keeping of all actions performed with personal data in such information systems is ensured;
Records of machine-readable personal data carriers are maintained;
In cases prescribed by law, information protection means shall be applied;
Identified threats to the security of personal data during their processing in the information systems of personal data of Semchenko and Partners LLC;
Facts of unauthorized access to personal data are identified and necessary measures are taken to comply with legal requirements and suppress unauthorized access to personal data;
The security regime of the premises where personal data information systems are located is organized, preventing the possibility of uncontrolled entry or stay in these premises of persons who do not have the right of access to these premises;
Other measures stipulated by the legislation of the Russian Federation in the field of personal data.

When processing personal data, LLC «Semchenko and Partners» takes legal, organizational and technical measures provided for in Article 19 of the Law on Personal Data to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data.

8. Contacts and details of Semchenko & Partners LLC.

197022, St. Petersburg, Akademika Pavlov St., 7, liter A, room 396-N. E-mail address: office@semchenko.su.