This Privacy Policy (hereinafter referred to as the “Policy”) was elaborated by the Joint-Stock Company ALRUD, having its registered office at: 7 Lesnaya street, 12th floor, Moscow, Russian Federation (hereinafter referred to as “ALRUD” or “we”), to provide a detailed description of our approaches to processing of personal data that we collect and process when you use our website www.alrud.com (hereinafter referred to as the “Website”).
While processing your personal data in connection with the Website use, being a personal data controller (as defined below) ALRUD acts in accordance with the laws and regulations of the Russian Federation for the protection of information and personal data (in particular, Federal Law dated July 27, 2006 No. 152-FZ “On Personal Data”, Decree of the Government of the Russian Federation dated November 1, 2012 No. 1119 “On Approving the Requirements to Protecting Personal Data Processed in Information Systems of Personal Data”, etc.).
This Policy is governed by Russian law.
1 TERMS AND DEFINITIONS
Below you may find definitions of certain terms used herein.
Personal data controller means a legal entity, separately or jointly with other entities, arranging and (or) carrying out personal data processing, as well as determining the purposes of personal data processing, scope of personal data to be processed, actions (operations) performed on personal data. ALRUD is a data controller with regard to your personal data.
Personal data means any information relating to directly or indirectly identified or identifiable individual (personal data subject). You (as a Website user) are a personal data subject.
Confidentiality of personal data means a mandatory requirement for ALRUD or any other persons having access to personal data not to permit distribution of such data without the data subject’s consent or without any other legal ground.
Processing of personal data means any action (operation) or set of actions (operations) performed on personal data with the use of automated means or without such, including collection, recording, systematization, accumulation, storage, specifications (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blockage, deletion or destruction of personal data.
Non-automated processing of personal data means any action with personal data, provided that the use, specifications, dissemination and destruction of personal data carried out with the direct participation of an individual.
Automated processing of personal data means personal data processing with the use of computer equipment.
Destruction of personal data means actions resulted in impossibility to recover personal data in the information systems of personal data and (or) actions resulted in destruction of personal data mediums.
Cross-border transfer of personal data means transfer of personal data to the territory of a foreign state to the governmental authorities of such foreign state, to foreign individual or foreign legal entity.
Depersonalization of personal data means actions resulted in impossibility to identify a particular individual to whom personal data relates without use of additional information.
Blockage of personal data means any temporary termination of personal data processing (except for cases where processing is required for specification of personal data).
Information system of personal data means personal data contained in the databases of personal data along with information technologies and technical means used for processing of personal data.
Special categories of personal data means data relating to race, national origin, political, religious or philosophic beliefs, state of health and sexual life.
Biometric personal data means information on physiological and biological characteristics of an individual allowing identification of such individuals and used by the personal data controller for the purpose of identification.
2 WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES?
You may use our Website to learn about ALRUD law firm, our team, our practice areas, our services, awards, vacancies and internships posted thereon. On our Website, you may also find the latest news regarding ALRUD law firm, newsletters and digests about changes and trends in legislation and law enforcement practice. All this you can do without providing any information about yourself to us, and we will not process your personal data, except for the data collected automatically (as described in Section 5 of this Policy). In addition, we will not process your biometric personal data and special categories of personal data.
At our Website, you may find certain functions that you may use, only if we perform the processing of your personal data. In that case, we will only process the data provided by you, except for the details collected automatically (as described in Section 5 of this Policy). We will not obtain your personal data from any third parties and will not process such data.
Below you will find a description of the cases where we perform the processing of your personal data in connection with the Website use, as well as types of such personal data and purposes of its processing:
2.1 Subscription to e-mail newsletters We constantly monitor any changes and trends in legislation and law enforcement practice and use our best efforts to provide our current and potential clients with such information. To do so, our team regularly prepares information materials (newsletters and digests) and holds related seminars.
We will be glad to share this information with you. To do so, you may subscribe to our newsletters in the relevant Website section. We will request your consent to processing of your personal data for delivering of marketing and other information materials to you after you have subscribed to our newsletters and in other cases where you use the functionality of our Website. We will not deliver such materials, if you do not provide your express consent thereto.
In addition, you may withdraw your consent to the processing of your data for receipt of marketing and other information materials at any time. In this case, we will immediately cease processing of your data. We will also ensure that upon receipt of each marketing letter from us, you will be able to opt out from receipt of such communications in the future.
While subscribing to newsletters, ALRUD collects the following categories of personal data directly from you: first and last names, employment and job title, e-mail address, details regarding your preferences in respect of types of information, practices, industries and news that you would like to receive.
2.2 Sending applications to us to get registered for events
ALRUD regularly holds seminars and events devoted to important legal issues, court rulings and relevant trends. You may send an application for registration to any of such events by completing a special electronic form on the Website.
While you complete an application form on the Website, we will request your consent to processing of the following categories of your personal data collected through this form: first, middle (if any and at your discretion) and last names, employment and job title, e-mail address and phone number.
We will process your personal data provided in such application form to ensure your registration for ALRUD’s event, which is of your interest. This includes communication with you to confirm your registration, to deal with organizational issues related to the event and your participation therein, to remind you of the upcoming event you have registered for, and to respond to any questions that you may have in this regard.
We will not deliver any information and invitations to other events, unless you have given your express consent to receipt of such information from us. We will separately request such consent from you in seminar application form. To find out more about our approach with regard to marketing and other information materials, please read Section 2.1 of this Policy.
2.3 Registration of ALRUD alumni
We try to maintain friendly relations not only within our firm, but also with our former employees who continue their professional career outside of ALRUD. To maintain such links, share news with each other and invite former colleagues to our events, we have started the ALRUD Alumni project.
We will be glad, if you are a former employee of our team and want to join our ALRUD Alumni project. In that case, you may use the relevant functionality of our Website to file an application for registration in ALRUD Alumni.
When you complete an application for registration in the ALRUD Alumni, we will request your consent to processing of your personal data. To complete your registration, we will request you to provide your first, middle (if any and at your discretion) and last names, e-mail address and phone number, indicate ALRUD’s practice you worked for, your current employment and job title and hyperlinks to your accounts on social media (if any and at your discretion).
We will process the personal data you have provided to deliver to you the information regarding events for ALRUD’s former employees and invitations to such activities, interaction with you on current business issues, for example, if we need to contact you for any assistance. We will not process your personal data for delivering of any marketing and other information materials to you, unless you have given your express consent thereto. We will separately request such consent from you in ALRUD Alumni registration form. To find out more about our approach with regard to marketing and other information materials, please read Section 2.1 of this Policy.
2.4 Filing an application for internship with ALRUD
ALRUD is interested in developing the potential of young specialists and recruiting them to our team. To do so, ALRUD periodically opens internship programs for students and graduates from law schools and universities. If you are interested in and want to apply to our internship program, you may use the functionality of our Website and complete a special application form posted thereon.
The consideration of your candidacy for internship implies that we process your personal data. In the application form we will request you to provide the following personal data: first, middle (if any and at your discretion) and last names, e-mail address and phone number.
You may attach a reference to your CV posted on the Internet or enclose a file containing your CV to your application. In that case, we will process your personal data contained in such CV. Prior to your filing an application with us, we will additionally request your consent to the processing of personal data.
If you file an application for internship, we will process your personal data solely to ensure your participation in such internship, including to evaluate your candidacy, to contact you in order to deal with any issues arising on consideration of your candidacy and other organizational issues, as well as to communicate the candidacy evaluation results to you.
2.5 Filing an application for employment with ALRUD
We seek to constantly grow and develop professionally. We understand that doing so is impossible without a team of highly qualified specialists. We are interested in recruiting new personnel to our professional team and, to do so, regularly post descriptions of vacancies on our Website in respect of specialists we are mostly interested in hiring.
If you want to join our team, you may submit your application with the use of the relevant functionality of our Website by indicating your first, middle (if any and at your discretion) and last names and your e-mail address, as well as by inserting a reference to your CV on the Internet or to the file containing your CV.
In this case, we process your data for considering the possibility of entering into an employment contract with you at your initiative. Prior to your filing an application with us, we will additionally request your consent to the processing of personal data.
We will process your personal data for the purpose of assisting you in your employment, including for evaluating your candidacy, for contacting you to deal with any issues arising on consideration of your candidacy and other organizational issues, as well as for communicating the results of your candidacy evaluation to you.
3 LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA
ALRUD processes personal data only if the relevant legal grounds for such processing exist. In addition to legal grounds described in Section 2 of this Policy above, ALRUD processes your personal data in the following cases:
To perform the functions, authorities and duties imposed on ALRUD by the Russian legislation.
To perform a contract to which you are a party, beneficiary or guarantor and (or) to enter into a contract at your initiative, or the contract to which you will be a beneficiary or guarantor.
To exercise rights and preserve legitimate interests of ALRUD or any third parties, including in cases provided for by the federal legislation of the Russian Federation.
Any other legal grounds as per Russian legislation.
4 HOW DO WE PROCESS YOUR PERSONAL DATA?
We perform the processing of your personal data both with and without the use of automated means (mixed processing). When processing your personal data, we perform the following actions (operations) on such personal data: collection, recording, systematization, accumulation, storage, specifications (updating, modification), retrieval, use, transfer (provision, access), including cross-border transfer of such data to the territory of the Netherlands where our backup services are located, depersonalization, blockage, deletion or destruction of personal data.
Upon collection of your personal data, we comply with the so-called localization requirement and ensure that recording, systematization, accumulation, storage, specifications (updating, modification) and retrieval of your personal data are performed with the use of databases located on the territory of Russia.
5 INFORMATION ABOUT YOU THAT IS COLLECTED AUTOMATICALLY. USE OF COOKIES
To improve the Website functioning and to make it easier to use, ALRUD may use the special cookies technology. ALRUD understands that to a certain extent cookies shall be treated as personal data, and operations on them shall be governed by the respective laws and regulations. In this section of the Policy, you may find out what cookies are and how ALRUD uses them.
What are cookies?
Cookies are small files that the Website stores on your device and use them to record certain actions on the Website by way of storing data that may be updated and restored. Those files are stored on your device and contain data harmless to your equipment. They are used to record your preferences, such as the selected language and access details, as well as to personalize the Website for you.
Cookies may also be used to store information about ways of your Website use. For example, from which page or promotion banner you have switched to the Website.
What types of cookies does ALRUD use and for which purposes?
Session cookies: temporary cookies that are stored among cookie files of your browser until you leave the page; these files are not stored on your hard drive. The details obtained with the help of such files help us analyze the directions of network traffic. In the long run, they help ALRUD to improve the Website content and facilitate its use.
Permanent cookies: these files are stored on a hard drive, and the Website recognizes them each time you access it. Permanent cookies have a limited term. Upon expiry of such term, these files cease to operate. Permanent cookies allow the Website to memorize information and settings for further visits of users, thus making web browsing easier and quicker due to, for example, the absence of the need to repeatedly enter registration data.
Technical cookies: technical cookies are required for the proper functioning of the Website and correct use of various personal opportunities and services offered thereon. For example, such cookies may be used to render technical support of a session, to exercise control over the response time, to operate or confirm personal preferences, to use security elements, to transfer data via social media, etc.
Personalization cookies: these cookies enable us to select or personalize certain Website features, such as through the selection of language, country settings or browser type.
Analytical cookies: ALRUD uses cookies to obtain information about browser settings and to analyze your behavior on the Website to improve its performance.
In particular, ALRUD uses the following instruments, which implies the use of analytical cookies:
Google Analytics, additional information about analytical tools provided by Google may be found at: https://www.google.com/analytics/.
Yandex.Metrika, you may find additional information about Yandex.Metrika at: https://yandex.ru/support/metrika/.
Social media cookies: To facilitate your exchanging of any content with the Website with the help of various social media, there are special buttons on the Website. The existence of such buttons means that the social network to which they are linked sets up cookies that are not under control of ALRUD but are used to launch your session in a social network, perform maintenance of such session or may show how many time users have shared specific materials in such social network. ALRUD recommends you to regularly read the rules of all social media in respect of confidentiality and use of cookies and, where applicable, change confidentiality parameters of social media so that to restrict the amount of data provided and adjust such parameters in accordance with your own interests.
When visiting the Website, you may see advertisements of our services, and the cookies file will be installed on your browser, using which ALRUD may analyze its advertisements, in particular, the number of views, exact place and time of their appearance, etc.
It may turn out that certain cookies placed on the site are not associated with ALRUD. This may be the case since certain pages contain elements obtained from third-party pages. Since such elements are obtained from other pages, ALRUD cannot exercise control over the configuration of such cookies. If you want to change your preferences in respect of any settings of cookies, you should visit such third-party websites for obtaining the relevant information.
Your opportunities of managing cookies
We will request your separate consent to processing of cookies. If you fail to give such consent, we will process only technical cookies that are necessary for the proper functioning of our Website.
You may withdraw your consent to processing cookies and delete cookies stored on your computer at any time by changing your browser settings. Below you will find links to additional information about ways of changing settings of the relevant browser.
Chrome (ENG): https://support.google.com/chrome/answer/95647?hl=en.
Explorer (ENG): https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies.
Firefox (ENG): https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences.
Safari (ENG): https://support.apple.com/en-gb/guide/safari/sfri11471/mac.
Finally, if you want to exercise control over the installation of cookies, you may install special programs or plug-ins, known as “Do Not Track” tools, on your browser for you to select which cookies you permit to store on your device.
6 HOW LONG DO WE PROCESS YOUR PERSONAL DATA?
We process your personal data no longer than it is necessary to achieve the purposes of processing established by the Policy.
Once the purposes of personal data processing have been achieved, ALRUD will destruct personal data (and cause such destruction by third parties involved in processing) within 30 days. We will also cease processing of your personal data (and cause destruction of such data by third parties involved in processing), if you withdraw your consent to data processing (where such consent is the only legal ground for processing of your personal data).
Please bear in mind that in certain cases we may continue processing your data after you have withdrawn your consent, where such processing is necessary to perform our duties arising from applicable laws or where such processing is required to exercise rights and legitimate interest of ALRUD and/or any third parties.
If you want to withdraw your consent to processing personal data, please send an e-mail to info@alrud.com.
7 ARE ANY THIRD PARTIES INVOLVED IN PROCESSING YOUR PERSONAL DATA?
Transferring personal data as part of business processes
As of today, doing business implies involving numerous specialists and advisors for technical and other issues, as well as using complicated information systems and IT infrastructures, including in connection with processing your personal data and maintaining confidentiality and protection of such data.
By engaging such third parties where required by laws and by instructing them to perform personal data processing on our behalf, being a personal data controller ALRUD ensures that third parties maintain confidentiality of your data and take the relevant organizational, legal and technical measures to protect such data. Third parties that we involve process your personal data solely for the purposes of rendering the relevant services to us and perform the operations on your personal data that we assign to them. Under no circumstances such third parties shall perform the processing of your personal data for the purposes that are contradictory to the purposes specified in this Policy.
Compliance with laws, court and administrative procedures and disclosure duties
ALRUD may transfer your personal data in the following cases (where it is required by, and not contradictory to, applicable laws):
To comply with applicable laws, court rulings and requests from any competent governmental authorities.
In connection with any ongoing investigation.
For the purposes of investigating or assisting in preventing any violations of applicable laws and this Policy.
To protect rights, property and to maintain safety of ALRUD and our employees, Website users or other persons, as well as in other cases covered by applicable laws.
If you need more information about third parties involved in processing of your personal data and/or with which we share your personal data, please send the relevant request to info@alrud.com, and we will deliver the required information to you.
8 THIRD-PARTY WEBSITES
The Website may contain hyperlinks to any third-party websites, while any third-party websites may contain hyperlinks to our Website.
ALRUD is not responsible for processing of your personal data on such third-party websites, as well as for any policies and practices applied by their owners, administrators or other persons in respect of processing personal data of users.
In light of this, we strongly recommend you to review the terms of use and privacy policy of each such third-party website that you visit.
9 WHAT MEASURES ARE IMPLEMENTED BY ALRUD TO PROTECT YOUR PERSONAL DATA?
Maintaining the confidentiality and security of your personal data is one of ALRUD’s key principles of personal data processing. To do so, ALRUD implements and will implement adequate technical, legal and organizational security measures in respect of your personal data, in particular:
Appoint the person responsible for arranging personal data processing, as well as the person in charge of ensuring security of personal data in the information system.
Issue local regulations in respect of personal data processing.
Enter into agreements with persons involved in personal data processing as instructed by ALRUD pursuant to the provisions of the Federal Law “On Personal Data”.
Evaluate damage that may be caused to Website users in the event of violation of Russian data protection laws, correlate such damage and taken measures aimed at ensuring security of personal data.
Introduce employees directly involved in processing of personal data with the provisions of Russian laws on personal data, ALRUD’s local regulations on personal data processing issues and/or hold trainings for such employees.
Keep regularly updated records of all persons having access to the systems storing personal data, with an indication of data processing procedures that they are entitled to perform.
Grant unlimited access to this Policy.
Prevent uncontrolled access into the premises where the information system that processes your personal data is located (including by installing locks on doors to such premises, access control system, use of the video surveillance system in cases permitted by laws).
Protect information with the help of special data protection means (including with the use of a software firewall, contemporary data exchange methods, granting protected remote access via external communication networks).
Introduce proper mechanisms, including user names and secret passwords, to secure access to personal data on a need-to-know basis.
Verify and take measures to make sure that each person entitled to access systems and/or folders storing personal data is aware of his/her duties and processing procedures related to such data, as well as of the relevant liability.
Ensure performance of procedures of sending reports and resolving disputes, as well as measures taken to provide for the level of security established by this Policy.
Install anti-virus programs for personal data protection.
Establish restricted access to personal data processed in ALRUD’s information systems.
Keep regularly updated event logs with an indication of the name of the person responsible, time of event, consequences (if any) and acts taken in case of compromising personal data security.
Introduce proper procedures of duplicating and restoring personal data.
Ensure regular backups of personal data.
Prevent attempted access to the information system.
Perform the blocking and deletion of accounts of dismissed employees who had access to personal data for performance of their job duties.
Ensure uninterrupted power supply for devices used to access the information system.
Regulate and exercise control over the use of mobile devices in the information system.
Store tangible media containing personal data in fireproof metal cabinets or safes pursuant to the effective legislation of the Russian Federation.
In case of non-automated processing, personal data shall be separated from other information by keeping such data on separate tangible media or in special sections or fields on forms and letterheads that may contain personal data.
In case of non-automated processing, ALRUD shall not permit storing data processing purposes of which are knowingly incompatible on the same tangible medium. In case of such processing, different tangible media stored separately from each other are used to store personal data processed for incompatible purposes.
ALRUD’s employees in charge of non-automated personal data processing are notified of special aspects and rules of such processing.
ALRUD undertakes to take any other necessary legal, organizational and technical measures to protect personal data from illegal or accidental access, destruction, modification, blockage, copying, transfer, dissemination, as well as any other unlawful actions in respect of personal data, in particular, measures covered by the Federal Law dated July 27, 2006 No. 152-FZ “On Personal Data”, Decree of the Government of the Russian Federation dated November 1, 2012 No. 1119 “On Approving the Requirements to Protecting Personal Data Processed in Information Systems of Personal Data”.
10 YOUR RIGHTS IN CONNECTION WITH PERSONAL DATA PROCESSING
You have the following rights in respect of personal data processing performed by ALRUD:
To withdraw your consent to the processing of your personal data by ALRUD.
To require the specifications, exclusion or editing, as well as blockage and destruction by ALRUD of incomplete, inaccurate, outdated, illegally obtained or unnecessary personal data.
To access to your personal data and, in particular, to obtain the following details from ALRUD:
(i) categories of personal data being processed;
(ii) purposes of processing personal data;
(iii) details of the persons who have access to personal data or who may be granted with such access (except for ALRUD’s employees);
(iv) list of your personal data processed and the source of obtaining such data;
(v) terms of personal data processing, including retention term; and
(vi) other details pursuant to the effective legislation of the Russian Federation.
To require the notification by ALRUD of all persons to whom inaccurate or incomplete personal data was provided of all deletions, modifications or additions thereto.
To exercise any other rights related to personal data protection provided for by the effective legislation of the Russian Federation.
To withdraw your consent to personal data processing, you are required to send the relevant request to: info@alrud.com. Once your consent has been withdrawn, we will cease processing your data, destruct personal data and ensure destruction of such data by third parties involved in processing (except where further processing is required by applicable laws or may be performed on any other legal ground).
11 AMENDMENTS TO THE PRIVACY POLICY
ALRUD reserves the right to make amendments and updates to this Privacy Policy.
If we decide to introduce any amendments or updates to this Privacy Policy, we will publish such amendments or updates here so that you are always aware of our personal data processing practices. In case of any changes to our Privacy Policy, you will be notified thereof by e-mail.
If, pursuant to effective laws, any changes to this Privacy Policy require your consent to further processing of personal data in accordance with any amended provisions of this Privacy Policy, we will request such consent and enable you to refuse from accepting such amendments and further processing of your personal data by way of sending a relevant notice.
12 WHOM MAY I CONTACT ON ISSUES OF PERSONAL DATA PROCESSING AND THE EXERCISE OF MY RIGHTS?
For exercising your rights and on any issues related to personal data processing, you may send us a request: