Adopted on January 23, 2024
Privacy Policy
Date of adoption: January 23, 2024
This Privacy Policy (the "Policy") is adopted pursuant to the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" ("Personal Data Law") and applies to users of our website (the "Website") when using the Website and when sending information to the corporate e-mail addresses specified on the Website.
We act like personal data controller under the Personal Data Law because we process information about you.
Our name: "Kucher Kuleshov Maximenko & Partners" Limited Liability Company.
Our details: Primary State Registration No. (OGRN) - 1227700175713, Taxpayer No. (INN) - 9703081063.
Our address: 1st Krasnogvardeisky Drive, 21 bldg. 1, intercity territory (intercity municipality) of the city of federal importance municipal circuit Presnensky, Moscow, 123112, Russian Federation.
Our Website: kkmp.legal
You can email us if you have any questions regarding the processing of personal data: Moscow@kkmp.legal
We process your personal data solely for the purposes for which it was collected and we inform you about it.
Processing means any actions with personal data allowed by law with the use of automated decisions and (or) without such use. Processing includes but is not limited to collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), blocking, deletion, destruction, etc.
Please note that we do not process special categories of personal data (information relating to race, nationality, political opinions, religious or philosophical beliefs, health, intimate life) or biometric personal data (information that describes the physiological and biological characteristics of an individual and is used to identify that individual). We do not use photos (for example, if the photo is contained in a CV sent to the corporate email addresses listed on the Site) for identification purposes.
Also, we do not make decisions giving rise to legal consequences or affecting your rights and legitimate interests based solely on automated processing of personal data.
The following reflects basic information about what personal data we process, for what purposes, on what basis and until when.
(i) Subscription to the mailing list
We collect personal data from you if you subscribe to our newsletter by filling out a form on the Website.
Personal data that we process in this case: surname, first name, place of work, job title, e-mail address.
The basis of processing will be your consent to the processing of personal data.
We store your personal data as long as you subscribe to our newsletter. You can unsubscribe from the newsletter at any time. If you unsubscribe from the newsletter, we will stop processing personal data in question.
(ii) Operation of the Website
We automatically process cookies when you access and use the Site, using the Yandex.Metrica service, to ensure the work of the Site, analytics, and to improve functionality. Cookies are small files of letters and numbers that are created and stored by your browser when you visit the Site. This is necessary to personalize the Website based on visitors' preferences, for example, to match the language of the Site. In some cases, however, the use of cookies is necessary for the correct operation of the Site.
You can find more detailed information about cookies and the terms of cookie processing on the Yandex.Metrica website.
The basis of processing will be your consent to the processing of personal data. We note that by using the Site, you confirm your consent to the processing of personal data.
You can disable cookies in your browser at any time. You can find instructions at the following links: Google Chrome, Microsoft Internet Explorer, Mozilla Firefox, Safari. Please note that if you disable cookies, some of the functionality of the Website may no longer work.
(iii) Selection of a candidate for a vacant post
We will need your personal data if you are being considered for a vacant employee position or for an internship. We may receive your personal data if you send us a CV or if we receive a CV in our corporate email from a recruitment organization with whom we are working with.
The amount of personal data we may process in this case is determined by the content of your CV, which you compile yourself and we cannot determine it in advance. Usually this includes your surname, first name and patronymic, year, month, date and place of birth, nationality, city of residence, information about education, specialties, qualifications, academic and scientific degrees and awards, information on employment and general experience, places of work and titles of positions held, photo, but there may be other data as well.
The basis for processing will be your consent to the processing of personal data. Please note that by sending us your CV or other data on your own initiative, you confirm your consent to the processing of personal data. We also reserve the right to obtain written consent when you visit our office.
If we conclude a contract with you (employment or internship), your personal data will be processed on the basis of other local regulations as personal data of an employee or intern. If we do not conclude a contract with you, we will stop processing your personal data within 30 days of deciding on your CV.
(iv) Obtaining feedback/negotiation
We may obtain your personal data if you contact us (e.g. by email), including for the purposes of initiating contract negotiations or clarifying information.
The amount of personal data we may process in this case depends on the amount of information you provide in your contact with us, which we cannot determine in advance. In addition, we may ask for full name, surname and patronymic, place of work, job title, telephone number and e-mail address.
The basis for processing will be your intention to enter into a contract with us, our legitimate interest in entering into a contract with you or our other legitimate interest as a data controller of personal data.
We will stop processing personal data within 30 days of ceasing to interact with you on your application. If we enter into a contract with you, we will continue to process your personal data within the scope of the contract we have entered into.
(v) Conclusion and performance of the contract
We will need your personal data if we enter into a contract with you.
Personal data that we process in this case: name, surname, patronymic, telephone number, e-mail address, position held, tax residency, passport data, including series and number of the document, data on when and by whom the document was issued, year, month, date and place of birth, citizenship, registration address, bank details, as well as other personal data necessary for the conclusion and performance of the contract.
The basis of processing will be the contract with you.
We will stop processing personal data after the time period set by law for retaining contracts has expired. We are obliged to retain the information for this time in accordance with the legislation.
(vi) Visit to our office
We process your personal data to order a pass if you intend to visit our office.
Personal data that we process in the specified case: first name, surname, contact telephone number.
The basis for processing will be our legitimate interest in ensuring the safety of our employees, property, and information.
We will delete your personal data provided to order your pass within 30 days of your visit.
Under the Personal Data Law, you have the right to, among other things:
receive information about the processing of your personal data, including information about the list of personal data, the grounds, purposes and periods of processing, third parties to whom we disclose your personal data, and other information;
clarification of your personal data;
blocking and deleting your personal data;
appealing our actions or our failure to act;
withdrawal of consent to the processing of your personal data.
To exercise your rights, you can send us a free-form complaint (except for the right to receive information about the processing of your personal data) to the following address: Moscow@kkmp.legal.
If you want to receive information about the processing of your personal data, by virtue of Article 14, paragraph 3 of the Personal Data Law, your request must be made in electronic or written form and must contain the following information:
the number of the main document proving your identity or the identity of your representative;
information on the date of issuance of the document and the issuing authority;
information confirming that you have interacted with us or our Site;
your signature or the signature of your representative (if the request is submitted electronically, it must be signed with an electronic signature, not a handwritten signature).
If you contact us through a representative, we must identify and verify the representative's identity and credentials.
We will not disclose your personal data to third parties unnecessarily. However, where necessary to fulfil the purposes of processing, we may disclose data to third parties with your consent or as otherwise required by law. This may include, for example, our contractors who provide hosting and support services for information systems.
We may also share your personal data in other cases as permitted by law, such as with public authorities in the exercise of their powers.
The personal data we process is confidential information. To ensure the security of personal data, we:
approved the person responsible for personal data processing;
developed and adopted internal documents on personal data processing issues;
carry out internal control over compliance with the processing of personal data;
use only secure databases;
evaluate the effectiveness of the measures taken;
provide for a set of measures aimed at protecting confidential information when interacting with counterparties;
use modern technical means and software systems, take organizational measures to protect personal data from unauthorized access, unlawful processing or transfer, as well as from loss, distortion or destruction;
always check the adequacy of measures before establishing new processes for processing personal data;
define the rules of access to personal data, minimize and grant access only in cases of actual necessity, where possible, log actions with data in information systems;
evaluate the effectiveness and regularly review the measures taken;
do everything possible to identify vulnerabilities and security incidents of personal data;
train our employees in the rules and principles of data processing and data protection, provisions of Russian legislation, requirements for non-automated processing, and familiarize them with internal documents.
Use of the Website is not intended for minors. We do not process personal data of minors. We will stop processing personal data if we establish that personal data of a minor has been obtained by us.
The Policy may be amended. The current text of the Policy is available at the following address: https://kkmp.legal/en/policy/. We will notify you of any changes to the Policy on the Website.