This Personal Data Policy (“Policy”) has been developed in accordance with
applicable requirements of the RF Constitution, Federal Law on Personal Data of July 27, 2006, No.
152-FZ, and other Russian regulations pertaining to personal data protection.
This Policy defines the principles, purposes, procedures and terms relating
to processing of personal data of users of the Andrey Gorodissky & Partners (“AGP”) website, as
well as personal data security, confidentiality and protection measures.
The terms used herein have the same meanings as defined in the Federal Law on
Personal Data of July 27, 2006, No. 152-FZ.
This Policy is provided on the AGP website (“Website”) at www.agp.ru/en/ for unlimited public access and review.
Principles and Terms of Personal Data Processing
AGP follows the following principles when processing personal data:
Legality and equitable basis;
Processing is limited to attainment of
particular, predetermined legal purposes;
No personal data are processed for any
purpose inconsistent with the purpose of collection of such data;
No integration of databases containing
personal data that are processed for purposes inconsistent with each other;
Processed are only personal data that are
consistent with the purpose of processing thereof;
Content and scope of processed personal
data match the specified purpose of processing;
No processing of personal data that are
over and above the specified purpose of processing;
Ensuring that processed personal data are
accurate, sufficient and up-to-date for the purpose of processing thereof;
Personal data are stored in a personally
identifiable format only as long as it is required for the purpose of processing, unless a
longer period is required by a federal law or an agreement under which the personal data
subject is a party or beneficiary or surety;
Personal data are deleted or anonymized
upon attainment of the purpose of processing thereof or when attainment of such purpose is
no longer needed, unless otherwise provided for by federal law.
AGP processes personal data if at least one of the following conditions is met:
The subject of personal data has given
his/her consent for processing;
Processing of personal data is required
for fulfillment of an agreement under which the personal data subject is a party or
beneficiary or surety, or for making an agreement initiated by the personal data subject or
an agreement under which the personal data subject will be a party or beneficiary or surety;
Processing of personal data is required
for exercise of AGP’s rights and legal interests or for attainment of public purposes,
provided that such processing does not violate rights and freedoms of the personal data
subject;
Personal data are processed for statistic
or other research-related purposes provided that such personal data are anonymized;
Other conditions set by applicable Russian
laws.
Purposes of Personal data Processing
AGP processes personal data exclusively for the purposes for which they are provided by the
Website users, inter alia for:
Sending AGP’s news and analytical
materials, informational, referential or marketing mailouts or alerts on AGP events to the
email addresses provided by the Website users;
Enabling a Website user to receive an
answer from AGP, where the user contacts AGP by sending an email to any of the email
addresses indicated on the Website;
Enabling a Website user seeking for a
vacancy at AGP to be invited for interviews, or for any other purpose which is not
inconsistent with applicable Russian law.
By providing his/her personal data, a Website user acknowledges his/her consent for processing
of such data for purposes for which they are provided.
Personal Data Content
AGP only processes the Website users’ data provided by the users on their own accord.
Content of personal data processed by AGP depends on which personal data are provided by the
Website users. Personal data provided by the Website users, that can be processed by AGP, may
include surname, first name, patronymic, email address, telephone number, place of job, job
position, education, age, and other personal data received on an AGP’s corporate email address
indicated on the Website.
The Website users give their consent for processing of such data by clicking “send” when
sending a relevant email containing their personal data. By providing their personal data, the
Website users acknowledge their consent for processing.
Whn using the Website, AGP may automatically collect from time to time certain anonymized
technical information about the Website visits and usage, including time and date and duration of
visits, number of visited Website pages, click-throughs, browser type, etc. These metrics are used
for purely statistical purposes, in particular for improvement of the Website performance and
analysis of AGP marketing efforts. Such data are anonymized and cannot be used to personally
identify the Website users.
Website User’s Rights
Website user has the right to request and receive from AGP information with respect to
processing of his/her personal data, to the extent that such right is not limited by applicable law.
Website user may request that AGP to update or block or delete his/her personal data if they
are incomplete, outdated, inaccurate or illegally obtained or not required for the specified purpose
of processing, and may use remedies afforded by law to protect his/her rights.
Website user may use applicable procedures to appeal against unlawful action or inaction during
processing of his/her personal data.
Website user may revoke his/her consent for processing of personal data by giving a written
notice to Znamenka str. 19, bldg. 3, 3rd floor, Moscow 119019, Russia, or office@agp.ru.
AGP Rights and Obligations
In the course of processing of personal data of the Website users, AGP may collect, record,
systemize, accumulate, store, amend (update or change), retrieve, use, transfer (distribute, make
available or provide access to), anonymize, block, delete or destroy the Website users’ personal
data.
Personal data may not be disclosed to any third parties other than AGP’s successors in the
event of its reorganization or persons authorized by it to process personal data or authorized
government agencies or persons whom AGP is required to disclose personal data to meet Russian laws
or to persons whom AGP transfers personal data for the purpose of fulfillment of an agreement made
with the Website user or to other persons with the Website user’s consent.
In case the Website users participate in any AGP arranged event, AGP may disclose relevant
personal data of the Website users to persons involved in arrangement of such event.
AGP undertakes to give persons receiving the Website users’ personal data a prior notice that
such data may only be used for the purposes for which they have been provided, and request that such
persons certify the fulfillment of such requirement.
AGP undertakes to not disclose the Website users’ personal data for any commercial purpose
without their consent. The Website users’ personal data may not be processed for promotion of any
products, work or services through direct telecommunications contact with potential consumers
otherwise than with the Website users’ prior consent.
AGP undertakes to ensure security of processed personal data and take legal, organizational and
technical measures required for protection of the Website users’ personal data.
Personal Data Security
The following measures are taken to prevent unauthorized access to, deletion, change, blocking,
copying, disclosure or distribution of or other unlawful activities with regard to the Website
users’ personal data:
Appointment of persons responsible for
organizational arrangements concerning processing of personal data;
Implementation of legal, organizational
and technical measures for security of personal data;
Use of secured premises and locked filing
cabinets;
Use of antivirus software;
Employees directly involved in processing
of the Website users’ personal data are aware of this Policy and the personal data
provisions of Russian laws;
Monitoring the administration of the
personal data protection measures.
Miscellaneous
The Website users’ personal data are processed as long as required for the purpose for which
they have been provided, unless a longer period is required by Russian laws.
AGP collects, records, systemizes, accumulates, stores, amends (updates or changes) or
retrieves personal data of the Website users being Russian citizens, using databases located in the
territory of the Russian Federation.
AGP does not control and is not responsible for any third party’s websites which may be
accessed by the Website users via links appearing on the Website.
Any other rights and obligations of the Website user and AGP shall be in accordance with
personal data laws of the Russian Federation.
Any issues of processing of the Website users’ personal data that are not expressly covered by
this Policy shall be subject to the personal data provisions of the Russian laws.
This Policy may be revised at any time by AGP on its discretion.
