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BBNP Privacy and Data Protection Policy

1. General Provisions

1.1. This Privacy and Data Protection Policy (the "Policy") approved by BBNP, LLC ("BBNP") establishes the main principles, goals, procedure, terms and conditions for processing of personal data of the Website Visitors, measures to ensure 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, laws and regulations of the Russian Federation related to personal data and is published for unrestricted access on BBNP's website at www.bbnplaw.ru.

1.3. The terms used in this Policy shall be interpreted in accordance with their definitions specified in Federal Law of the Russian Federation No. 152-FZ dated 27/7/2006 On Personal Data.

1.4. BBNP guarantees that it will keep the received personal data confidential subject to the provisions of this Policy and use it only for the purposes specified in the Policy. 

2. Concept and Composition of Personal Data

2.1. The list of personal data to be protected by BBNP is formed in accordance with Federal Law of the Russian Federation No. 152-FZ 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.) of the Visitors of BBNP's Website – www.bbnplaw.ru (the "Website"), as well as personal data that is received by BBNP corporate emails ending in @bbnplaw.ru (the "Corporate Email") of the subjects who have given their Consent to the processing of their personal data (the "Consent") by sending information via the selected forms (the "Forms") on the Website pages or by sending emails. The Consent is accepted at the moment of ticking the relevant box in the Form and pressing the submit button of the Form on any page of the Website, as well as clicking on the button to send an email containing personal data of the subject to the Corporate Email.

2.3. When you browse BBNP's Website, read texts and download any other information, certain data about the computer from which the Website Visitor browsers BBNP's Website is registered automatically. While you browse the Website, BBNP collects the following information:
date and time of the Website visit;
number of pages visited, their names and duration of their viewing;
IP address assigned to the device for accessing the Internet; 
the type of browser and operating system;
the URL of the website that you clicked from. 

3. Purposes of Personal Data Processing

3.1. Personal data of the Website Visitors is processed for the following purposes: 
sending reference and marketing information to the Website Visitors by sending messages to the email addresses specified by the Website Visitors; 
providing Visitors with an opportunity for giving feedback to BBNP; 
providing the Website Visitors with advice on issues related to the services rendered for marketing activities and support of the Website Visitors, as well as for other purposes that do not contradict the current legislation of the Russian Federation and the terms and conditions of the agreements between BBNP and the relevant Website Visitors. 

4. Principles and Conditions for Personal Data Processing

4.1. The processing of personal data by BBNP is based on the following principles:
lawfulness and fair basis;
limitation to specific, explicit and legitimate purposes;
prevention of the processing of personal data inconsistent with the objectives of the personal data processing;
prevention of the merging of databases containing personal data the processing of which is carried out for the purposes inconsistent with each other;
the content and scope of the processed personal data shall correspond to the declared purposes of the processing;
personal data shall be stored in the form that allows identifying the personal data subject for no longer than required for the purpose of the processing of personal data if no retention period of personal data is stated by the Federal Law, the contract a party, beneficiary or guarantor to which is the personal data subject;
other principles provided for by the applicable laws of the Russian Federation on personal data.

4.2. BBNP may process personal data if at least one of the following conditions is met:
the personal data subject has given its Consent to the processing of personal data;
the processing of personal data is required for the exercise of the rights and legitimate interests of BBNP in order to achieve socially significant goals provided that the rights and freedoms of the personal data subject are not violated; 
the processing of personal data is carried out for statistical or other research purposes subject to mandatory depersonalization of personal data;
other conditions provided for by the applicable laws of the Russian Federation on personal data. 

5. Rights and Obligations of the Personal Data Subject

5.1. The personal data subject shall have the right to: 
request detailing, updating, blocking or destroying of his/her personal data; 
receive a list of his/her personal data processed by BBNP, the source of its receipt, information about the terms of processing of his/her personal data, including the terms of its storage and other information about the processing of his/her personal data; 
require notifying all persons who have been previously informed of his/her incorrect or incomplete personal data about all corrections or additions made; 
challenge in accordance with the established procedure against illegal actions or omissions in the processing of his/her personal data.

5.2. The Website Visitors shall provide only true and correct information about themselves.

5.3. The Consent to the processing of personal data is given by the Visitor for the entire period required for BBNP to achieve the objectives of processing.

5.4. The Visitor may revoke his/her Consent to the processing of personal data by sending a written application or by sending it to the Corporate Email (info@bbnplaw.ru).

5.5. Persons who have transmitted information to BBNP via the Website about another personal data subject without the consent of the subject whose personal data has been transmitted shall be held liable in accordance with the laws of the Russian Federation.

6. Rights and Obligations of BBNP

6.1. BBNP shall never ask the Website Visitors to provide information about their race, national origin, political opinions, religious or philosophical beliefs, state of health, intimate life. 

6.2. In the course of personal data processing, BBNP shall have the right to: collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transmit (distribute, provide, access), depersonalize, block, delete or destroy the Visitor's personal data.

6.3. If the Visitors participate in the events organized by BBNP, the latter shall have the right to disclose the relevant personal data of the Visitors to the persons participating in the organization of such an event.

6.4. BBNP shall not have the right to transfer personal data of the Website Visitors to any third party except for the following persons: 
authorised state bodies within their powers;
persons to whom BBNP has to pass it in order to comply with the laws of the Russian Federation;
persons to whom BBNP transfers personal data for the performance of a contract with the data subject;
persons to whom BBNP assigns the processing of personal data; 
the successors of BBNP in case of its reorganization;
other persons with the consent of the personal data subject. 

6.5. BBNP shall not have the right to disclose personal data of the Website Visitors for commercial purposes without their consent. The Visitor's personal data may be processed for the purpose of promoting goods, work and services on the market by making direct contacts with potential consumers via communication means only with the Visitor's prior consent.

6.6. BBNP shall warn the persons who receive the Visitor's personal data that this data can only be used for the purposes for which it has been provided and require these persons to confirm that this rule is observed.

6.7. Persons who have received the Visitor's personal data shall keep it confidential.

6.8. BBNP processes personal data of the Website Visitors and conducts activities on its protection in accordance with the provisions of this Policy, as well as other documents published by BBNP.

7. Ensuring the Protection and Security of Personal Data

7.1. BBNP applies the relevant standards of technological and operational security to protect information provided by the Website Visitors from unauthorized access, disclosure, distortion, blocking or destruction.

7.2. The measures used by BBNP include the following: 
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;
assessment of 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 premises with restricted access to host servers of personal data information systems, as well as the use of lockable cabinets for storing paper media of personal data; 
making sure that BBNP employees, who directly process personal data, read and understand the provisions of the laws of the Russian Federation on personal data; 
control over the measures taken to ensure the security of personal data.

7.3. Access to personal data shall be granted only to authorised employees of BBNP who have undertook to keep such information confidential.

8. Storage of Personal Data

8.1. Personal data of the Website Visitors shall be stored for the period necessary for the purposes for which such data has been provided or for the period stipulated by the laws.

8.2. Upon fulfilling the purposes/expiration of the period for processing of personal data, the personal data of Website Visitors shall be destroyed.

9. Log Information, Cookies and Web Beacons

9.1. BBNP's Website collects typical session log information, including the 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. In order to ensure effective Website management and assist in setting up the user interface, BBNP may use cookies (small text files stored in the user's browser) or web beacons (electronic images) in conjunction with tracking pixels, which allow the Website to count the number of visitors who have visited a particular page and provide access to certain cookies. 

The standard information collected shall be used exclusively for statistical purposes. BBNP shall not use personal data for the purposes of personal identification of any of the Visitors. However, when authorising registered Visitors to the site, BBNP may use this information in conjunction with information obtained through data analysis tools and cookies in order to analyse how visitors use the Website.

9.2. By using the Website, the Visitor agrees that BBNP can upload cookies to the User's device in accordance with the conditions mentioned 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 to refuse the use of cookies. If cookies are blocked, changes may affect the user interface and some components of the Website may become unavailable.

10. Final Provisions

10.1. This Policy shall be subject to change or addition in the case of relevant changes or additions to the applicable laws of the Russian Federation on personal data and may also be changed at any time at the discretion of BBNP. The current version of BBNP's 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 with regard to the processing and protection of personal data that are not directly stipulated in this Policy shall be regulated in accordance with the provisions of the applicable laws of the Russian Federation on personal data.

10.3. Compliance with the requirements of this Policy shall be monitored by the person responsible for organising the processing of personal data by BBNP. 

The Policy was last updated on April 23, 2020.