RGP Privacy Policy

  1. General Provisions
  2. Principles of personal data processing
  3. For what purposes does RGP use personal data
  4. What personal data does RGP collect
  5. Use of cookies and similar technologies
  6. Confidentiality and the security of Users’ personal data
  7. Cross-Border Data Transfers
  8. Website Users’ Rights and Obligations
  9. How long does RGP keep Users’ personal data for
  10. Final Provisions

1. General Provisions

This Privacy Policy (“Privacy Policy”) applies to all data that LLC Rybalkin, Gortsunyan & Partners (Primary State Registration Number – 1187746659539; Individual Taxpayer Number – 7743264648; Registered Office: Entrance C, 5th Floor, 2, Tsvetnoy Boulevard, Moscow, 127051, Russia) (“RGP”) having an Internet website with the domain name www.rgp.legal (“Website”) can get on persons who have access to this Website via the Internet and use this Website (“User”).

This Privacy Policy, adopted by RGP, sets out the purposes for which we process personal data of Website users (“Users”), the procedure and conditions for processing such data, the measures to secure and protect the personal data that RGP has under control and provides for an obligation not to disclose and to protect processed by RGP.

Relations concerning collection, storage, dissemination and protection of personal data are regulated by other RGP official documents and current legislation of the Russian Federation in the field of personal data.
Basic terms of this Privacy Policy are interpreted as defined in the Russian Federation Federal Law on “Personal Data” No. 152-FZ of 30 July 2006 (“Law on Personal Data”).

2. Principles of personal data processing

Principles of personal data processing are defined by current legislation of the Russian Federation in the field of personal data.

Personal data processing is subject to conditions described by current legislation of the Russian Federation in the field of personal data.

3. For what purposes does RGP use personal data

The purposes for which RGP uses personal data are as follows:

  1. to provide advice on services delivered by RGP;
  2. to provide relevant email or postal marketing and client support;
  3. to provide feedback for Users;
  4. to consider individuals for employment and contractor opportunities and manage on-boarding procedures;
  5. to improve the Website user experience and describe services delivered by RGP;
  6. to protect the security and effective functioning of the Website and information technology systems;
  7. to achieve other purposes in accordance with the current law of the Russian Federation.

4. What personal data does RGP collect

The categories of personal data RGP may collect from Users are defined in the Law on Personal Data.

RGP processes and protect Users’ personal data, including automatically captured data about the device of Internet access, as well as personal data sent to RGP corporate e-mail, subject to their consent.

RGP processes the following categories of personal data:

  1. basic data: last name, first name, middle name, organization, job title, phone number, mailing address, email address, details of public social media profiles, other contact details;
  2. registration data: RGP newsletter requests, RGP event registrations, subscriptions, downloads, and username/passwords;
  3. matter details: details of individuals instructing RGP; personal data included in correspondence, transaction documents, evidence or other materials that RGP processes in the course of providing services and legal advice; payment information and other information relevant to provision of services;
  4. recruitment data, including, but not limited to, name and job title, contact information; curriculum vitae containing relevant information and other information relevant to potential recruitment to RGP.
  5. consent records: records of any consents Users may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent);
  6. data relating to the Website and device data: Computer Internet Protocol (IP) address, unique device identifier (UDID), device type, language settings, type of browser and operating system, website URL, from which user is redirected, dates and times of connecting to the Website, cookies, and data about usage of the Website and other technical communication and statistic data.

This is a non-exhaustive list which is reflective of the varied nature of the personal data processed in the course of providing legal services by RGP.

5. Use of cookies and similar technologies

The Website, emails or advertising messages contain “Cookies”, or other technologies, such as “web beacons” or “pixel tags” which RGP collects to retain personal data while visiting the Website. This records are collected for the purposes of web-analytics and error management in connection to the Website.

By continuing to use the Website without altering browser settings, as well as by sending an email to RGP corporate email, Users are accepting this Privacy Policy and are agreeing to RGP’s using of these technologies. If Users do not wish to accept this Privacy Policy and (or) cookies and similar technologies in connection with the use of the Website, they must stop using the Website and (or) manage certain cookies in Internet browser settings.

RGP also uses Google Analytics. For further information on Google Analytics please visit marketingplatform.google.com/about/.

6. Confidentiality and the security of Users’ personal data

RGP implements technical and organizational measures in an effort to safeguard Users’ personal data in control of RGP from unlawful or accidental access thereto, destruction, modification, blocking, copying, disseminating thereof and other improper use by third parties.

Firm personnel and data processors, who have access to and (or) are associated with the processing of personal information, are obliged to respect the confidentiality of such personal information and comply with this Policy.

RGP shall inform Users if their personal data is lost or disclosed and take all measures necessary to prevent loss or other negative impact.

RGP may appoint sub-contractor data processors as required to deliver the services, such as, but not limited to, document processing and translation services, confidential waste disposal, IT systems or software providers, IT Support service providers, document and information storage providers, who will process personal information on behalf and at direction of RGP. RGP ensures that they process personal information appropriately.

If necessary, RGP may also appoint external data controllers to deliver the services, including, but without limitation, auditors, investment banks or lawyers in Russia or abroad, and other third party experts. When doing so RGP will comply with its obligations in respect of personal data in compliance with this Privacy Policy.

The Website may contain links to other websites personal data processing practices may be different than RGP’s. Before using such websites, users should consult these sites’ privacy notices or analogous documents. In such cases, RGP cannot guarantee compliance with this Privacy Policy, since it has no control over information that is submitted to, or collected by, these third parties.

7. Cross-Border Data Transfers

If necessary, we transfer personal to jurisdictions for the purposes described above, including to jurisdictions that may not adequate level of data protection as User’s home country. Such cross-border data transfers are governed by the Law on Personal Data.

By using the Website, Users consent to cross-border data transfers for the purposes of paragraph 4 of article 12 of the Law on Personal Data.

8. Website Users’ Rights and Obligations

Rights and obligations of RGP and Website Users concerning personal data are regulated by the Law on Personal Data.

When prescribed by law, Users have a right to access personal data associated with him and processed by RGP in accordance with this Policy.

Under certain conditions set out in current legislation, Users also have the following rights in relation to the personal information RGP holds about Users:

  1. right to rectification, blocking or erasure of their personal data, if the personal data RGP holds about them is incomplete, inaccurate or obsolete, or has been unlawfully received, or is not necessary for the mentioned above personal data process purposes;
  2. users’ right to take measures prescribed by law to protect thier personal data;
  3. right to request information concerning personal data processing;
  4. right to object to RGP’s processing of their personal data, if it is prescribed by legislation.

Users may have other rights that are not mentioned above, where law so provides.

Users can contact RGP via email sgortsunyan@rgp.legal in order to

  1. exercise the above-mentioned rights and rights stipulated in the Law on Personal data;
  2. submit a claim to RGP if they are not satisfied with RGP’s processing of Users personal data;
  3. get more information on this Policy.

RGP shall respond to Users’ requests in compliance with current legislation.

If Users consider that RGP processes their personal data in breach of the requirements of the Law on Personal Data or that RGP otherwise infringes on Users’ rights and freedoms, they have a right to lodge a complaint with the data protection authority or with the court about actions or omissions of RGP.

By using the Website, Users undertake to give only the trustworthy information about himself.

9. How long does RGP keep Users’ personal data for

For Users, RGP will retain relevant personal data for no longer than it is required for the purposes of processing such data, or in compliance with its obligations under relevant legislation.

Upon completion of data process purposes or upon the expiry of the above-mentioned period, RGP may then destroy such files without further notice of Users.

10. Final Provisions

RGP may make changes to this Privacy Policy, if necessary. To ensure that Users are always aware of how RGP uses Users’ personal data RGP will update this Privacy Policy from time to time to reflect any changes to RGP’s use of Users’ personal data. RGP may also make changes as required to comply with changes in applicable law or regulatory requirements.

RGP encourages Users to review this Privacy Policy periodically to be informed of how RGP uses Users’ personal data by following the link. RGP does not individually inform Users of modifications to Privacy Policy.

All relations involving RGP concerning personal data processing and not covered in this Privacy Policy are regulated in compliance with current legislation of the Russian Federation in the field of personal data.