Privacy Policy

Policy for the processing and protection of personal data of site users group of companies ZPARTNERS

Ensuring the confidentiality and security of personal data processing is one of the priorities of the ZPARTNERS group of companies.

1. General provisions

1.1. Policy for the processing and protection of personal data of website users
 (hereinafter - the Policy) was developed by the Limited Liability Company "ZetPartners Legal Group" (hereinafter - the Operator) in accordance with
 from Art. 24 of the Constitution of the Russian Federation, Federal Law of May 31, 2002
 No. 63-FZ “On advocacy and the legal profession in the Russian Federation”, Federal Law of July 27, 2006 No. 152-FZ “On personal data” and other regulatory legal acts in the field of personal data.

1.2. This Policy applies to all information that the Operator may receive about the user (hereinafter referred to as the User) and/or a third party
 on behalf of and in the interests of which the user acts - while using the site https://zpartners.ru its services.

1.3. The purpose of the Policy is to ensure the protection of rights and freedoms when processing personal data of the User and/or third parties on behalf of and in whose interests the User acts.

1.4. In accordance with Part 2 of Art. 18.1 of Federal Law No. 152-F3 “On Personal Data” (hereinafter referred to as the “Law on Personal Data”) on the need to post the Policy in the public domain and ensure unlimited access to it,
 this Policy does not contain detailed information about the measures taken
 on the protection of personal data by the Operator, as well as other information, the use of which by an unlimited number of persons may cause damage to the Organization or subjects of personal data.

1.4. Users of the site, using the services of the Operator, having provided the Operator with their personal data, including through the mediation of third parties, acknowledge their consent to the processing of personal data in accordance with this Policy.

1.5. Consent to the processing of personal data may be withdrawn by the subject of personal data. In case of withdrawal of consent by the subject of personal data
 for the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds provided for by current legislation.

1.6. The Operator publishes the Policy on the website at the address: https://zpartners.ru, and also provides unlimited access to it to any person who personally applies
 to the Operator.

1.7. This Policy applies only to the website https://zpartners.ru.

1.8. The operator does not control and is not responsible for third party sites,
 to which the User can follow links, including targeted advertising, available on the site https:// zpartners.ru.

2. Purposes of processing personal data

The purposes of processing personal data by the Operator are:

- ensuring the possibility of sending a response to questions sent by the User using a web form on the site (by contacting the Operator);

- ensuring the possibility of other feedback from the Operator’s employees
 with the User;

- ensuring the fulfillment of the obligations of the Operator’s employees to Users;

- organizing a call from the Operator’s employees to the User’s phone number;

- ensuring the functionality and security of the site;

- for other purposes, if the corresponding actions of the Operator do not contradict the current legislation, the activities of the Operator, and consent has been obtained for the said processing.

3. The concept of personal information of users

3.1. Within the framework of this Policy, the User’s personal information means:

3.1.1. Any personal information that the User provides independently in the process of using feedback forms, including: last name, first name, patronymic, telephone number, email address, as well as other information directly provided for in the Application - the User’s consent to the processing of personal data.

3.1.2. Data that is automatically transferred to site services in the
process  their use using software installed on the User’s device, including IP address, cookie data, information about the User’s browser (or other program through which services are accessed), technical informationcharacteristics of the equipment and software used by the User, date and time of access to services, addresses of requested pages and other similar information.

3.1.3. Data about the User’s geographic location, Internet service provider, data received from the User as a result of access to the camera, microphone, etc. devices.

3.1.4. Other information about the User, the processing of which is necessary for the purposes of using the site.

4. Principles for processing personal data

4.1. The Operator’s actions are carried out on the basis of the following principles:

- timeliness and reliability of obtaining consent to the processing of personal data;

- confidentiality;

- processing only personal data that meets the purposes of their processing;

- preventing the merging of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other;

- accuracy, sufficiency and appropriateness of processing personal data;

- the legality of technical measures aimed at processing personal data.

4.2. The processing of personal data by the Operator is carried out in compliance with the principles and rules, including those provided for:

- Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”;

- Decree of the Government of the Russian Federation dated November 1, 2012 No. 1119 “On approval of requirements for the protection of personal data during their processing in personal data information systems”;

- By Order of the FSTEC of Russia dated February 18, 2013 No. 21 “On approval of the composition of
 and the content of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems”;

- Order of Roskomnadzor dated September 5, 2013 No. 996 “On approval of requirements
 and methods for depersonalizing personal data”;

- Other regulatory and non-regulatory legal acts governing the processing of personal data;

- This Policy.

5. Obtaining personal data

5.1. The user is obliged to take a responsible approach to posting his own personal data on the site.

5.2. Personal data is obtained by the Operator:

- by sending the User a message by e-mail by filling out a form on the website, including when sending documents attached to the letter;

- by sending messages by telephone/fax by the User;

- by automatically collecting information about the User using
technologies  and services: web protocols, cookies, web tags, which are launched only when the User enters his data;

- by other means that do not contradict the legislation of the Russian Federation.

5.3. The operator receives and begins processing personal data from the moment of receiving his consent. Consent to the processing of personal data is given by the User through the combination of the following implied actions:

- by directly using (including viewing) the Operator’s website;

- consent (acceptance) with the Declaration of Consent form before sending the message by email, by checking the box “I have read the Policy for the Processing and Protection of Personal Data of Users of the Site https: //zpartners.ru
 and I consent to the processing of personal data.”

5.4. The user can withdraw his consent to the processing of personal data at any time. To revoke consent to the processing of personal data, you must submit a corresponding written statement to the Operator. At the same time, the Operator must stop processing them or ensure the termination of such processing even if the storage of personal data is no longer required
 for the purposes of their processing, destroy personal data or provide
 their destruction within a period not exceeding 30 (thirty) days from the date of receipt of the specified response application.

5.5. The User has the right to send a written request to the Operator
 on termination of processing of personal data. The operator is obliged to meet the deadline
 not exceeding 10 (ten) working days from the date of receipt of the relevant request, stop processing personal data or ensure the termination of such processing, except in cases provided for by current legislation. This period may be extended, but not more than by 5 (five) working days if the Operator sends a motivated notice to the User indicating the reasons for extending the period for providing the requested information.

5.6. If the User withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the User’s consent thenonly if there are grounds specified in the regulatory documents  and non-normative legal acts regulating the processing of personal data.

5.7. The user has the right to choose what personal data will be
 provided to them. However, in case of incomplete provision of the necessary data, the Operator does not guarantee the ability to use the services of the site to transfer to the Operator all the necessary information.

5.8. The User acknowledges, confirms and agrees that the technical processing and transmission of information on the Operator’s website may involve the transfer of data over various unprotected networks, including unencrypted Internet communication channels.

5.9. The User understands that any messages and/or information sent through the Operator's server may be unauthorized and/or illegally read and/or intercepted by third parties.

5.10. The operator is not responsible for the actions of third parties, unauthorized
 and/or illegally gained access to the User’s personal data,
 including through the fault of the latter.

5.11. The User has the right to receive from the Operator information regarding the processing of his personal data, including confirmation of the fact of processing of personal data by the Operator, the legal grounds and purposes of processing personal data, the purposes and methods of processing personal data used by the Operator, the name and location of the Operator, information about persons (except for the Operator’s employees) who have access to personal data or to whom personal data may be disclosed
 on the basis of an agreement with the Operator or on the basis of federal law, processed personal data related to the relevant User, as well as other information provided for by Federal Law
  dated July 27, 2006 No. 152-FZ “On Personal Data” or other federal laws. The specified information is provided to the User or his representative by the Operator within 10 (ten) business days from the date of application or receipt by the Operator of the request of the User or his representative. The specified period may be extended, but not more than by 5 (five) working days if sent by the Operator
 to the User a reasoned notification indicating the reasons for extending the period for providing the requested information. The User's request must contain the number of the main document identifying the User
 or his representative, information about the date of issue of the specified document and the issuer
 his body, information confirming the participation of the subject of personal data
 in relations with the operator (contract number, date of conclusion of the contract, conventional verbal designation and (or) other information), or information otherwise confirming the fact of processing of personal data by the operator, signature of the User or his representative.

6. Conditions for processing personal data of Users and its transfer to third parties.

6.1. Confidentiality is maintained with respect to the User's personal information, except in cases where the User voluntarily provides information about himself for general access to an unlimited number of persons. In this case, the User agrees that a certain part of his personal information becomes publicly available.

6.2. The User's personal data is stored exclusively on electronic media and processed using automated systems,
 except for cases where non-automated processing of personal data is necessary in connection with compliance with legal requirements.

6.3. When processing the User’s personal data, the Operator ensures the use of databases located on the territory of the Russian Federation.

6.4. The operator processes personal data by performing any action (operation) or set of actions (operations) performed
 using automation tools or without using such tools, including the following: collection; recording; systematization; accumulation; storage; clarification (update, change); extraction; usage; transmission (distribution, provision, access); depersonalization; blocking; deletion; destruction.

6.5. Processing and storage of Users’ personal data is carried out
 for the period of time necessary for the purposes for which such data was provided, or for the period required by law, or
 until the User revokes his consent to the processing of personal data.

6.6. The Operator guarantees organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, etc.distribution, as well as
 from other unlawful actions by third parties.

6.7. The operator does not sell or provide personal data to third parties
 including for marketing purposes.

6.8. The Operator destroys the User’s personal data in the following cases:

- the presence of a threat to the security of the site, including if there are signs of unauthorized and/or illegal administration of the site by third parties;

- at the User's request.

6.9. The Operator has the right to transfer the User’s personal information to third parties in the following cases:

- the user has expressed consent to such actions;

- the transfer is necessary for the User to use a certain service or to fulfill a certain agreement or contract with the User;

- the transfer is provided for by Russian legislation within the framework of the procedure established by law.

7. Special conditions

7.1. In the event of any disputes or disagreements related to the implementation of this Policy, the User and the Operator will make every effort to resolve them through negotiations between them. If disputes are not resolved through negotiations, disputes shall be resolved in the manner established by the current legislation of the Russian Federation.

7.2. The provisions of this Policy come into force for the User from the moment he begins using (including viewing) the Operator’s website and is valid
 for an indefinite period.

7.3. The provisions of this Policy may be changed and/or supplemented by the Operator at any time during its validity period at its discretion
 without the need to obtain the User’s consent. All changes
 and/or additions are posted by the Operator in the appropriate section of the website
 and come into force on the day of such posting. The user undertakes to promptly
 and familiarize yourself with all changes and/or additions.
 If the User disagrees with the changes made, he is obliged to refuse access to the site and stop using the materials and services of the site.

8. Feedback, questions and suggestions 

8.1. All suggestions, questions and notices regarding this Policy should be sent to the email address: info@zpartners.ru or to the address:
 101000, Moscow, Gusyatnikov lane, 4, building 3, room. 2.

8.2. The appeal must contain the following information:

- number of the main identification document of the User;

- information about the date of issue of the specified document and the issuing authority;

- information confirming the User’s participation in relations with the Operator;

- User signature.

The operator undertakes to consider and send a response to the received request within 30 (thirty) days from the date of receipt of the request.

8.3. The appeal must contain the following information: - number of the main document identifying the subject of personal data; - information
 about the date of issue of the specified document and the issuing authority; - information confirming the participation of the subject of personal data in relations with the Operator; - signature of the subject of personal data. The organization undertakes to consider
 and send a response to the received request within 30 (thirty) days from the date of receipt of the request.

8.4. All correspondence received by the Organization from the subject of personal data in written or electronic form is classified as restricted information and is not disclosed without his written consent.