PERSONAL DATA PROCESSING POLICY

1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of Federal Law Nr. 152-FZ On Personal Data, dated July 27, 2006. It defines the procedures for processing personal data and measures to ensure personal data security, to be taken by West Garant, the Law firm in Moscow (hereinafter, the “Processor”).

1.1. The Processor sets themselves the primary goal and condition of performing their activities to respect personal and civil rights and liberties when processing personal data, including the protection of rights to privacy.
1.2. This Processor’s personal data processing policy (hereinafter, the “Policy”) shall apply to all information the Processor may gain regarding the visitors of the http://lbwg.ru website.
 
2. Basic Terms and Definitions
2.1. Automated Personal Data Processing shall mean processing personal data by means of computer technology;
2.2. Blocking of Personal Data shall mean the temporary termination of the personal data processing, except if such processing is necessary to rectify the personal data;
2.3. Website shall mean a set of graphic and information materials, as well as computer programs and data bases that make such materials available on the Internet at: http://lbwg.ru;
2.4. Personal Data System shall mean a set of personal data contained in the databases and information technology and engineering tools ensuring processing the same;
2.5. Rendering Personal Data Anonymous shall mean any actions that result in making it impossible, without using any additional information, to identify any personal data as belonging to a specific User or another personal data owner;
2.6. Personal Data Processing shall mean any action/operation or a set of actions/operations performed with or without automation tools towards personal data, including collecting, recording, categorizing, accumulating, storing, detailing (updating or modifying), extracting, using, transferring (distributing, providing, or accessing), depersonalizing, blocking, deleting, and destructing any personal data;
2.7. Processor shall mean a public authority, a municipal body, a legal entity or an individual that, independently or jointly with other entities/individuals, arranges and/or performs personal data processing, as well as defines the purposes of personal data processing, the composition of personal data to be processed, and actions/operations to be performed regarding personal data;
2.8. Personal Data shall mean any information relating to a directly or indirectly determined or being determined User of the http://lbwg.ru website;
2.9. User shall mean any visitor of the http://lbwg.ru website;
2.10. Providing Personal Data shall mean any actions aimed at disclosing personal data to a certain person or a group of persons;
2.11. Personal Data Dissemination shall mean any actions aimed at disclosing personal data to an unspecified group of persons (personal data transfer) or at making the personal data available to general public, including disclosing the personal data in mass media, posting the same in information and telecommunication networks, or providing any access to the personal data in any other manner;
2.12. Cross-Border Transfer of Personal Data shall mean transferring personal data to a foreign jurisdiction, a foreign authority, a foreign individual, or a foreign legal entity; 
2.13. Erasing Personal Data shall mean any actions resulting in securely destroying personal data, in which it would be impossible to further restore the personal data within the personal data system, and/or in destroying the physical media containing personal data.
 
3. Processor shall be entitled to process the following personal data of the User:
3.1. Surname, first name, patronymic;
3.2. E-mail address;
3.3. Phone numbers;
3.4. Our website also collects and processes anonymized information on the visitors, including the cookies, using web analytics services, such as Yandex.Metrica, Google Analytcis, etc.
3.5. Hereinafter, the above data shall be defined by a common concept of “Personal Data.”
 
4. Personal Data Processing Purposes
4.1. The purpose of processing the User’s personal data is to notify the User by sending emails; and to conclude, execute, and terminate civil contracts.
4.2. Processor shall also be entitled to notify the User about any new products and services, special offers, and various events. User shall be entitled to opt out any Processor’s notifications by sending the Processor an email to info@lbwg.ru, marked “Waiver of Notice regarding Any New Products or Special Offers.”
4.3. Anonymized User data collected using the web analytics services is used to gather information on the Users’ actions on the website and to improve the website quality and contents.
 
5. Legal Grounds for Personal Data Processing
5.1. Processor shall only process the User’s personal data if the latter one has been filled out and/or sent by the User independently via spacial forms located on the http://lbwg.ru website. Filling out the relevant forms and/or sending their personal data to the Processor, the User agrees to comply with this Policy.
5.2. Processor shall process the User’s anonymized data, provided that such processing is enabled in the User’s browser settings, i.e., that saving cookies and using the JavaScript technology are enabled.
 
6. Procedures for Collecting, Storing, Transferring, and Otherwise Processing Personal Data

Security of personal data to be processed by the Processor shall be ensured by implementing the necessary legal, organizational, and technical measures for completely complying with the requirements of the current personal data protection legislation.

6.1. Processor shall ensure the security of personal data and take all possible measures to prevent any unauthorized persons from accessing to personal data.
6.2. The User’s personal data will never and in no circumstances be transferred to any third parties, except in cases related to implementing applicable legislation.
6.3. Should any incorrectness be detected in their personal data, the User shall be entitled to update it independently by notifying the Processor to the Processor’s e-mail address info@lbwg.ru, marked “Personal Data Update.”
6.4. Personal data processing period shall be unlimited. User may withdraw their consent to their personal data processing at any time by notifying the Processor via email to the Processor’s e-mail address info@lbwg.ru, marked “Personal Data Processing Consent Withdrawal.”
 
7. Cross-Border Personal Data Transfer
7.1. Prior to the commencement of cross-border personal data transfer, the Processor shall make sure that the foreign country, to which jurisdiction the personal data is supposed to be transferred, provides a reliable protection of personal data owners’ rights.
7.2. Cross-border personal data transfer to any foreign jurisdictions that do not meet the above requirements may only be performed, provided there is the personal data owner’s consent in writing to such cross-border transfer of their personal data and/or execution of an agreement, in which the personal data owner is a party.
 
8. Final Provisions
8.1. User may get any clarifications of the issues of their interest regarding their personal data processing by contacting the Processor via email at: info@lbwg.ru.
8.2. Any changes in the Processor’s personal data processing policy will be covered hereby. This Policy shall remain in force indefinitely, until it is replaced by an updated version.
8.3. The current version of the Policy is freely available on the Internet at: http://lbwg.ru/privacy.

Addresses of the offices:

Moscow, 24/2, Malaya Dmitrovka Street

Branch in Kazan:

Kazan 420107, Spartakovskaya Street