1. General provisions
1.1. This Personal Data Processing Policy (hereinafter referred to as the Policy), adopted by BBNP LLC (hereinafter referred to as BBNP), defines the basic principles, goals, procedure and conditions for processing personal data of Site Visitors, measures to ensure the security and protection of personal data.
1.2. This Policy has been developed in accordance with the requirements of the Constitution of the Russian Federation, legislative and other regulatory legal acts of the Russian Federation in the field of personal data and is published for unrestricted access on the BBNP website at www.bbnplaw.ru.
1.3. The terms used in this Policy are interpreted according to their definition in Federal Law of the Russian Federation No. 152-FZ of July 27, 2006 “On Personal Data”.
1.4. BBNP guarantees confidentiality with respect to the personal data received in accordance with the provisions of this Policy and undertakes to use it only for the purposes specified in the Policy.
2. The concept and composition of personal data
2.1. The list of personal data subject to protection by BBNP is compiled in accordance with Federal Law No. 152-FZ of the Russian Federation dated July 27, 2006 “On Personal Data”.
2.2. BBNP processes and protects personal data (including last name, first name, place of work, position, contact phone number, email address, etc.) Visitors to the BBNP Website www.bbnplaw.ru (hereinafter referred to as the Site), as well as personal data sent to the BBNP corporate email address ending in @bbnplaw .ru (hereinafter referred to as the Corporate Mail), subjects who have expressed their Consent to the processing of personal data (hereinafter referred to as the Consent) by sending information through selected forms (hereinafter referred to as the Forms) on the Site pages or by sending an e-mail. The moment of acceptance of the Consent is to mark the relevant field in the Form and click on the Form submit button on any page of the Site, as well as click on the button to send an email containing the subject's personal data to the Corporate Mail address.
2.3. While browsing the BBNP Site, reading texts and downloading other information, certain data is automatically recorded about the computer from which the Site Visitor is viewing the BBNP Site. When you browse the Site, BBNP collects the following information:
the date and time of your visit to the Site;
the number of pages visited, their titles, and the length of time they were viewed;
The IP address assigned to the device for accessing the Internet;
browser type and operating system;
The URL of the site from which the link was made.
3. Purposes of personal data processing
3.1. The processing of personal data of Site Visitors is carried out for the following purposes:
sending reference and marketing information to Site Visitors by sending messages to the email address specified by Site Visitors;
providing visitors with opportunities for feedback from BBNP;
providing Site Visitors with advice on issues related to the services provided for marketing activities and supporting Site Visitors, as well as for other purposes that do not contradict the current legislation of the Russian Federation and the terms of agreements between BBNP and relevant Site visitors.
4. Principles and conditions for the processing of personal data
4.1. BBNP's processing of personal data is based on the following principles:
legality and a fair basis;
limiting the achievement of specific, predetermined and legitimate goals;
preventing the processing of personal data that is incompatible with the purposes of collecting personal data;
preventing the merger of databases containing personal data that are processed for purposes that are incompatible with each other;
the content and volume of personal data processed must comply with the stated purposes of processing;
personal data is stored in a form that makes it possible to identify the subject of personal data for no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor;
other principles provided for by the current legislation of the Russian Federation on personal data.
4.2. BBNP processes personal data under at least one of the following conditions:
the personal data subject has given Consent to the processing of personal data;
the processing of personal data is necessary to exercise the rights and legitimate interests of BBNP in order to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject;
personal data is processed for statistical or other research purposes, subject to mandatory anonymization of personal data;
other conditions provided for by the current legislation of the Russian Federation on personal data.
5. The rights and obligations of the personal data subject
5.1. The personal data subject has the right to:
demand that your personal data be clarified, updated, blocked or destroyed;
receive a list of your personal data processed by BBNP, the source of its receipt, information about the processing time of your personal data, including its storage periods, and other information about the processing of your personal data;
require that all persons who were previously informed of his incorrect or incomplete personal data are notified of all corrections or additions made;
appeal in accordance with the established procedure against illegal actions or omissions in the processing of his personal data.
5.2. Site visitors are obliged to provide only accurate information about themselves.
5.3. Consent to the processing of personal data is issued by the Visitor for the entire period necessary for BBNP to achieve the processing goals.
5.4. Consent to the processing of personal data may be withdrawn by the Visitor by sending a written application or to the Corporate Mail address (info@bbnplaw.ru).
5.5. Persons who submit information to BBNP through the Site about another personal data subject without the consent of the subject whose personal data was transferred are liable in accordance with the legislation of the Russian Federation.
6. BBNP rights and obligations
6.1. BBNP never asks the Site Visitor for information about his race, nationality, political views, religious and philosophical beliefs, health status, or intimate life.
6.2. During the processing of personal data, BBNP has the right to: collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (distribute, provide, access), anonymize, block, delete, and destroy the Visitor's personal data.
6.3. If Visitors participate in events organized by BBNP, the latter has the right to disclose the relevant personal data of Visitors to persons involved in organizing such an event.
6.4. BBNP is not entitled to transfer the personal data of Site Visitors to third parties, except for the following persons:
authorized state bodies within their powers;
persons to whom BBNP is obliged to transfer them in order to comply with Russian legislation;
persons to whom BBNP transfers personal data in order to perform an agreement with a personal data subject;
individuals to whom BBNP entrusts the processing of personal data;
BBNP's legal successors during its reorganization;
other persons, with the consent of the personal data subject.
6.5. BBNP is not entitled to disclose the Site Visitor's personal data for commercial purposes without his consent. The processing of the Visitor's personal data in order to promote goods, works and services on the market by making direct contacts with a potential consumer using communication tools is allowed only with the prior consent of the Visitor.
6.6. BBNP undertakes to warn persons who have received the Visitor's personal data that this data can only be used for the purposes for which it was disclosed and require these persons to confirm that this rule has been complied with.
6.7. Persons who have received the Visitor's personal data are required to maintain secrecy (confidentiality).
6.8. BBNP processes and takes measures to protect the personal data of Site Visitors in accordance with the provisions of this Policy, as well as other documents issued by BBNP.
7. Ensuring the protection and security of personal data
7.1. BBNP uses appropriate technological and operational security standards to protect information provided by Site Visitors from unauthorized access, disclosure, distortion, blocking or destruction.
7.2. The measures used by BBNP include:
appointment of a person responsible for organizing the processing of personal data;
application of legal, technical and organizational measures to ensure the security of personal data;
assessing the harm that may be caused to personal data subjects in case of violation of legal requirements, the ratio of harm and security measures taken by BBNP;
use of secure rooms with restricted access to host personal data information system servers, as well as the use of lockable cabinets for storing paper personal data;
familiarizing BBNP employees who directly process personal data with the provisions of the legislation of the Russian Federation on personal data;
control over measures taken to ensure the security of personal data.
7.3. Access to personal data is provided only to authorized BBNP employees who are committed to maintaining the confidentiality of such information.
8. Personal data storage
8.1. The personal data of Site Visitors is stored for the period necessary for the purposes for which such data was provided or for the period provided by law.
8.2. Upon reaching the goals/expiration of the period for processing personal data, the personal data of Site Visitors is destroyed.
9. Log information, “cookies” and “web beacons” technologies
9.1. The BBNP website collects typical session log information, including IP address, browser type and language, as well as data about the time of visit and the address of the websites from which the links were clicked. To ensure effective management of the Site and assist in customizing the user interface, BBNP may use cookies (small text files stored in the visitor's browser) or web beacons (web beacons — electronic images) together with tracking pixels to allow the Site to count the number of visitors that visit a particular page and provide access to certain cookies.
The collected sample information is used exclusively for statistical purposes. BBNP does not use personal data to personally identify any of the Visitors. However, when logging in to the Site, BBNP may use this information in combination with data analysis tools and cookies to analyse how visitors use the Site.
9.2. By using the Site, the Visitor agrees that BBNP can download cookies to the Visitor's device in accordance with the conditions described above.
9.3. The visitor can manage cookies by accessing the browser settings. If cookies are deleted, all data about the Visitor's preferences will be deleted, including the preference not to use cookies. If cookies are blocked, changes may affect the user interface and some components of the Site may become inaccessible.
10. Final provisions
10.1. This Policy is subject to change or supplement when appropriate changes or additions are made to the current legislation of the Russian Federation on personal data, and may also be changed at any time at the discretion of BBNP. The current version of the BBNP Policy is always available for viewing by an unlimited number of people on the website at the permanent address: www.bbnplaw.ru.
10.2. All relations involving BBNP related to the processing and protection of personal data that are not directly reflected in this Policy are regulated in accordance with the provisions of the current legislation of the Russian Federation on personal data.
10.3. Compliance with the requirements of this Policy is monitored by the person responsible for organizing the processing of personal data by BBNP.
The Policy was last updated on October 01, 2020.