Privacy Policy and Personal Data Processing Policy for users of the website slf.demo.mtfy.xyz/en
Operator: Moscow Bar Association "Sobranie" (abbreviated as MBA "Sobranie"); INN 9703177872, OGRN 1247700276449; address: 44 Sadovnicheskaya St., bldg. 1, Zamoskvorechye Municipal District, Moscow, 115035; e-mail: info@slf.ru; telephone: +7 (495) 799-67-00.
1. General Provisions
1.1. This Policy defines the procedure and conditions for the processing of personal data of users of the website slf.demo.mtfy.xyz/en, individuals submitting inquiries via website forms, as well as recipients of informational and promotional communications.
1.2. The Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data," Federal Law No. 38-FZ dated March 13, 2006, "On Advertising," and other applicable regulatory legal acts of the Russian Federation.
1.3. The Policy is a publicly available document and is posted on the website. It applies solely to data processing in connection with the use of the website and does not replace the Operator's internal documents governing the processing of data of clients, employees, attorneys, contractors, and other categories of subjects outside the website.
1.4. Use of the website to view publicly available information does not require the user to provide a name, telephone number, or other contact details. Refusal of non-essential analytical cookies and newsletters does not restrict access to the main content of the website.
2. Key Definitions
In this Policy, the terms "personal data," "operator," "processing of personal data," "automated processing," "provision," "dissemination," "blocking," "deletion," "destruction," and "anonymization" are used in the meanings established by Federal Law No. 152-FZ.
A cookie is a small piece of data stored by the browser on the user's device. Similar identifiers may be stored in localStorage. Such information may constitute personal data if it allows for the direct or indirect identification of the user.
3. Categories of Subjects and Composition of Processed Data
3.1. The Operator processes personal data of the following categories of subjects: website visitors; persons who have submitted an inquiry via the form; persons who have contacted the firm using the contact details provided on the website; and persons who have separately consented to receive informational and promotional communications.
3.2. When completing the feedback form, the following may be processed:
3.4. For distribution lists, the following may be processed: name; phone number; email address; identifier and contact in the selected messenger; selected communication channels; history of messages sent; information regarding consent to and opt-out from distributions.
3.5. The Operator does not carry out the targeted collection of biometric data or special categories of personal data via the website, including information regarding health, intimate life, racial or ethnic origin, political views, religious or philosophical beliefs, or information regarding criminal records. The form is not intended for the transmission of passport data, bank details, copies of documents, information constituting a legally protected secret, or the personal data of third parties.
1. General Provisions
1.1. This Policy defines the procedure and conditions for the processing of personal data of users of the website slf.demo.mtfy.xyz/en, individuals submitting inquiries via website forms, as well as recipients of informational and promotional communications.
1.2. The Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ dated July 27, 2006, "On Personal Data," Federal Law No. 38-FZ dated March 13, 2006, "On Advertising," and other applicable regulatory legal acts of the Russian Federation.
1.3. The Policy is a publicly available document and is posted on the website. It applies solely to data processing in connection with the use of the website and does not replace the Operator's internal documents governing the processing of data of clients, employees, attorneys, contractors, and other categories of subjects outside the website.
1.4. Use of the website to view publicly available information does not require the user to provide a name, telephone number, or other contact details. Refusal of non-essential analytical cookies and newsletters does not restrict access to the main content of the website.
2. Key Definitions
In this Policy, the terms "personal data," "operator," "processing of personal data," "automated processing," "provision," "dissemination," "blocking," "deletion," "destruction," and "anonymization" are used in the meanings established by Federal Law No. 152-FZ.
A cookie is a small piece of data stored by the browser on the user's device. Similar identifiers may be stored in localStorage. Such information may constitute personal data if it allows for the direct or indirect identification of the user.
3. Categories of Subjects and Composition of Processed Data
3.1. The Operator processes personal data of the following categories of subjects: website visitors; persons who have submitted an inquiry via the form; persons who have contacted the firm using the contact details provided on the website; and persons who have separately consented to receive informational and promotional communications.
3.2. When completing the feedback form, the following may be processed:
- name;
- phone number;
- email address, if additionally provided by the user;
- preferred method of communication;
- text of the brief inquiry;
- date, time, page, and form of submission of the inquiry;
- IP address, browser and device data, technical logs of form transmission;
- information regarding consents provided, their versions, date, time, and method of confirmation.
3.4. For distribution lists, the following may be processed: name; phone number; email address; identifier and contact in the selected messenger; selected communication channels; history of messages sent; information regarding consent to and opt-out from distributions.
3.5. The Operator does not carry out the targeted collection of biometric data or special categories of personal data via the website, including information regarding health, intimate life, racial or ethnic origin, political views, religious or philosophical beliefs, or information regarding criminal records. The form is not intended for the transmission of passport data, bank details, copies of documents, information constituting a legally protected secret, or the personal data of third parties.
4. Purposes, Scope of Data, and Legal Grounds
5. Procedure, Methods, and Conditions of Processing
5.1. Processing is carried out using automation tools, without such tools, and by mixed methods. The Operator is entitled to perform the following actions: collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer (provision, access) to persons acting on behalf of the Operator, depersonalization, blocking, deletion, and destruction.
5.2. The Operator does not disseminate personal data to an indefinite circle of persons and does not make decisions that give rise to legal consequences for the subject solely on the basis of automated processing.
5.3. Access to data is provided only to authorized employees and other persons to the extent necessary for the performance of their duties. Such persons are obliged to maintain confidentiality and comply with security requirements.
5.4. When collecting personal data of citizens of the Russian Federation, the recording, systematization, accumulation, storage, clarification, and extraction are carried out using databases located within the territory of the Russian Federation.
6. Persons processing data on behalf of the Operator
6.1. For the operation of the website and forms, the Operator uses the Tilda platform. Processing on behalf of the Operator is carried out by JSC "Tilda Publishing" (TIN 9707041449, PSRN 1247700830354; postal address: 127051, Moscow, Tsvetnoy Blvd, 21, bldg. 1, P.O. Box 44). Within the platform infrastructure, JSC "Selectel" and LLC "Yandex.Cloud" may be engaged, whose servers are located in the Russian Federation.
6.2. For analytics purposes, YANDEX LLC (16 Lev Tolstoy St., Moscow, 119021) is utilized via the Yandex Metrica service, counter No. 108326355, including the Session Replay (Webvisor) function. Regarding visitor data, Yandex acts on behalf of the Operator within the terms of use of the service.
6.3. Inquiries may be transmitted to the Operator's corporate email. When engaging a corporate email provider, CRM, or mailing service, the Operator ensures the existence of a contract or an instruction for the processing of personal data and reflects significant changes in this Policy prior to the commencement of the relevant processing.
6.4. Transfer to state authorities, courts, and other parties is permitted in cases and according to the procedure provided for by the legislation of the Russian Federation, as well as when necessary for the establishment, exercise, or defense of rights and legitimate interests.
6.5. Planned cross-border transfer of website user data is not performed. Should the need for such a transfer arise, the Operator will fulfill the requirements established by law prior to its commencement, including notification of the authorized body, if mandatory.
7. Processing Periods and Destruction
8. Rights of the Personal Data Subject
The subject shall have the right to:
9. Security Measures
The Operator shall implement necessary and sufficient legal, organizational, and technical measures, including:
10.1. Essential technical cookies are used for the loading, security, and functioning of the website. They are not used for advertising profiling and are processed regardless of consent for analytics in the minimum necessary volume.
10.2. Yandex Metrica and Webvisor are activated only after a separate positive selection by the user in the cookie banner. The user must have an equivalent opportunity to accept or reject analytical cookies and subsequently change their choice.
10.3. The detailed composition of data, timeframes, and the method of withdrawal are provided in a separate document titled "Consent to the use of cookies and data collection by analytics services."
11. Final Provisions
11.1. The Policy is effective from the moment of publication on the website. The Operator is entitled to amend it in the event of changes in legislation, data composition, purposes, processing methods, or services used.
11.2. The new version enters into force on the date specified in the document, unless a different period is provided. For processing that requires consent, material changes do not apply to previously obtained consent without obtaining new consent, where required by law.
Contacts for personal data inquiries: info@slf.ru; +7 (495) 799−67−00; 115035, Moscow, intracity territory Zamoskvorechye municipal district, Sadovnicheskaya st., 44, bldg. 1.
5.1. Processing is carried out using automation tools, without such tools, and by mixed methods. The Operator is entitled to perform the following actions: collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer (provision, access) to persons acting on behalf of the Operator, depersonalization, blocking, deletion, and destruction.
5.2. The Operator does not disseminate personal data to an indefinite circle of persons and does not make decisions that give rise to legal consequences for the subject solely on the basis of automated processing.
5.3. Access to data is provided only to authorized employees and other persons to the extent necessary for the performance of their duties. Such persons are obliged to maintain confidentiality and comply with security requirements.
5.4. When collecting personal data of citizens of the Russian Federation, the recording, systematization, accumulation, storage, clarification, and extraction are carried out using databases located within the territory of the Russian Federation.
6. Persons processing data on behalf of the Operator
6.1. For the operation of the website and forms, the Operator uses the Tilda platform. Processing on behalf of the Operator is carried out by JSC "Tilda Publishing" (TIN 9707041449, PSRN 1247700830354; postal address: 127051, Moscow, Tsvetnoy Blvd, 21, bldg. 1, P.O. Box 44). Within the platform infrastructure, JSC "Selectel" and LLC "Yandex.Cloud" may be engaged, whose servers are located in the Russian Federation.
6.2. For analytics purposes, YANDEX LLC (16 Lev Tolstoy St., Moscow, 119021) is utilized via the Yandex Metrica service, counter No. 108326355, including the Session Replay (Webvisor) function. Regarding visitor data, Yandex acts on behalf of the Operator within the terms of use of the service.
6.3. Inquiries may be transmitted to the Operator's corporate email. When engaging a corporate email provider, CRM, or mailing service, the Operator ensures the existence of a contract or an instruction for the processing of personal data and reflects significant changes in this Policy prior to the commencement of the relevant processing.
6.4. Transfer to state authorities, courts, and other parties is permitted in cases and according to the procedure provided for by the legislation of the Russian Federation, as well as when necessary for the establishment, exercise, or defense of rights and legitimate interests.
6.5. Planned cross-border transfer of website user data is not performed. Should the need for such a transfer arise, the Operator will fulfill the requirements established by law prior to its commencement, including notification of the authorized body, if mandatory.
7. Processing Periods and Destruction
- inquiry data on the Tilda platform — for the period established in the form settings, but no more than 90 calendar days;
- inquiries and correspondence that did not result in the conclusion of a legal services agreement — until the purpose is achieved, but no more than 3 years from the date of the last substantive interaction;
- data transitioned into relations under a legal services agreement — within the timeframes established by separate documents, the agreement, and legislation;
- technical security logs — no more than 12 months, unless longer storage is required for incident investigation or compliance with the law;
- analytical data — until withdrawal of consent, removal of the counter, or expiration of the storage period determined by Yandex Metrica settings; the terms for individual cookies are specified in the consent for the use of cookies;
- contact details for mailings — until withdrawal of consent; evidence of consent and refusal — up to 3 years after the cessation of mailings.
8. Rights of the Personal Data Subject
The subject shall have the right to:
- receive information regarding the processing of their personal data;
- demand the rectification, blocking, or destruction of incomplete, outdated, inaccurate, unlawfully obtained, or excessive data;
- withdraw consent and demand the cessation of processing carried out on the basis of consent;
- opt out of mailings and change the settings for analytical cookies;
- appeal the actions or omissions of the Operator to Roskomnadzor or to a court;
- exercise other rights provided for by the legislation of the Russian Federation.
9. Security Measures
The Operator shall implement necessary and sufficient legal, organizational, and technical measures, including:
- appointment of a person responsible for organizing the processing of personal data;
- adoption of local regulations, definition of purposes, data categories, retention periods, and access procedures;
- restriction and accounting of access, application of authentication tools and backup procedures;
- risk assessment, monitoring of measure effectiveness, and training of personnel authorized to process data;
- incident detection, data recovery, and interaction with Roskomnadzor in cases established by law;
- masking of form fields from recording by Webvisor and blocking of analytics until consent is obtained.
10.1. Essential technical cookies are used for the loading, security, and functioning of the website. They are not used for advertising profiling and are processed regardless of consent for analytics in the minimum necessary volume.
10.2. Yandex Metrica and Webvisor are activated only after a separate positive selection by the user in the cookie banner. The user must have an equivalent opportunity to accept or reject analytical cookies and subsequently change their choice.
10.3. The detailed composition of data, timeframes, and the method of withdrawal are provided in a separate document titled "Consent to the use of cookies and data collection by analytics services."
11. Final Provisions
11.1. The Policy is effective from the moment of publication on the website. The Operator is entitled to amend it in the event of changes in legislation, data composition, purposes, processing methods, or services used.
11.2. The new version enters into force on the date specified in the document, unless a different period is provided. For processing that requires consent, material changes do not apply to previously obtained consent without obtaining new consent, where required by law.
Contacts for personal data inquiries: info@slf.ru; +7 (495) 799−67−00; 115035, Moscow, intracity territory Zamoskvorechye municipal district, Sadovnicheskaya st., 44, bldg. 1.