— 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:
The processing of personal data includes, but is not limited to:
The operator shall have the right to:
The operator is obligated to:
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: firstname.lastname@example.org.
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:
Representatives of legal entities:
Purpose of processing:
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:
Purpose of 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:
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.
6.1 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).
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:
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.
197022, St. Petersburg, Akademika Pavlov St., 7, liter A, room 396-N. E-mail address: email@example.com.