Privacy policy

I. General Information

This Privacy Policy (hereinafter referred to as the "Policy") has been adopted in accordance with Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as the – “Personal Data Law”) and applies to visitors of the website kkmp.legal (hereinafter referred to as the “Website”) when using the Website and when sending information to the corporate email addresses listed on the Website.

II. About Us

Under the Personal Data Law, we are considered a personal data operator because we process information about you.

Our name: Kucherov, Kuleshov, Maksimenko and Partners LLC.

Our details: Primary State Registration Number – 1227700175713, Taxpayer Identification Number – 9703081063.

Our address: 123112, Moscow, Presnensky Municipal District, 1st Krasnogvardeysky Proezd, Building 21, Structure 1 (Moscow-City, Oko Tower).

Our website: kkmp.legal

If you have any questions regarding the processing of personal data, you can contact us at: Moscow@kkmp.legal

III. Processing of Personal Data

We process your personal data solely for the purposes for which they were obtained and of which we inform you.

"Processing" means any operation performed with personal data that is permitted by law, carried out with or without the use of automated means. Processing includes, but is not limited to, collection, recording, organization, accumulation, storage, updating (renewal, modification), retrieval, use, transfer (dissemination, provision, access), blocking, erasure, and destruction.

Please note that we do not process special categories of personal data (information concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, health status, intimate life) or biometric personal data (information characterizing physiological and biological features of a person and used to establish their identity). We do not use photographs we possess (for example, if a photograph is contained in a resume sent to the corporate email address listed on the Website) for identification purposes.

Furthermore, we do not make decisions based solely on automated processing of personal data that produce legal consequences or otherwise significantly affect your rights and legitimate interests.

The following reflects the key information regarding what personal data we process, for what purposes, on what legal basis, and for how long.

(i) Subscription to Newsletter

We receive personal data from you when you subscribe to our newsletter by filling out a form on the Website.

The personal data we process in this case includes: last name, first name, place of work, and email address.

The legal basis for processing is your consent to the processing of personal data.

We retain your personal data as long as you remain subscribed to our newsletter. You may unsubscribe from the newsletter at any time. Once you have unsubscribed, we will cease processing the said personal data.

(ii) Website Operation

To ensure the operation of the Website, perform analytics, and improve functionality, we automatically process cookies when you access and use the Website through the Yandex.Metrica service. Cookies are small files consisting of letters and numbers that are created and stored by your browser when you visit the Website. This is necessary to personalize the Website based on visitor preferences, for example, to select the Website's language. In some cases, the use of cookies is a necessary condition for the proper operation of the Website.

For more detailed information about cookies and the terms of cookie processing, you can visit the Yandex.Metrica website.

The legal basis for processing is your consent to the processing of personal data. Please note that by using the Website, you confirm your consent to the processing of personal data.

You may disable cookies in your browser at any time. Instructions can be found at the following links: Google Chrome, Microsoft Internet Explorer, Mozilla Firefox, Safari. Please note that if you disable cookies, some functionality of the Website may cease to work.

(iii) Candidate Selection for a Vacant Position

We will need your personal data if you participate in the selection process for a vacant employee or intern position. We may receive your personal data if you send us your resume, or if we receive a resume at our corporate email address from a recruitment agency with which we cooperate.

The scope of personal data we may process in this case is determined by the content of your resume, which you prepare yourself, and we cannot determine it in advance. This typically includes last name, first name, and patronymic (if applicable); year, month, date, and place of birth; citizenship; city of residence; information about education, specializations, qualifications, academic degrees and awards; information about work and total employment history; places of work and job titles held; photograph; but other data may also be included.

The legal basis for processing is your consent to the processing of personal data. Please note that by sending us your resume or providing 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, as a result of the selection process, a contract (employment or internship agreement) is concluded with you, your personal data will be processed on the basis of other local regulations as personal data of an employee or intern. If a contract is not concluded with you, we will cease processing your personal data within 30 days from the date a decision is made regarding your resume.

(iv) Receiving Feedback / Conducting Negotiations

We may receive your personal data if you contact us (for example, by email), including for the purpose of initiating negotiations to conclude a contract or to clarify certain information.

The scope of personal data we may process in this case depends on the amount of information you provide in your communication to us, which we cannot determine in advance. Additionally, we may request your last name, first name, patronymic (if applicable), place of work, position, telephone number, and email address.

The legal basis for processing will be your intention to enter into a contract with us, our legitimate interest to enter into a contract with you, or another legitimate interest of ours as a personal data operator.

We will cease processing your personal data within 30 days after the interaction with you regarding your inquiry has ended. If we enter into a contract with you, we will continue to process your personal data within the framework of that concluded contract.

(v) Conclusion and Performance of a Contract

We will need your personal data if we enter into a contract with you.

The personal data we process in this case includes: first name, last name, patronymic (if applicable), telephone number, email address, position held, tax residency, passport data including the series and number of the identification document, information on when and by whom the document was issued, year, month, date and place of birth, citizenship, registration address, bank account details, as well as other personal data necessary for the conclusion and performance of the contract.

The legal basis for processing will be the contract concluded with you.

We will cease processing your personal data after the expiration of the period established by law for the retention of contracts. We are required to retain the information during this period in accordance with the law.

(vi) Visiting Our Office

We process your personal data to arrange a visitor pass if you intend to visit our office.

The personal data we process in this case includes: first name, last name, and contact telephone number.

The legal basis for processing will be our legitimate interest in ensuring the security of our employees, property, and information.

We will delete your personal data provided for arranging the visitor pass within 30 days after your visit.

IV. Your Rights

In accordance with the Personal Data Law, you have the right, among others:

to obtain information regarding the processing of your personal data, including details about the list of personal data, the legal bases, purposes and periods of processing, third parties to whom we transfer your personal data, as well as other information;
to have your personal data updated (corrected);
to have your personal data blocked and erased;
to appeal our actions or our inaction;
to withdraw your consent to the processing of personal data.

To exercise your rights, you may send us a request in free form (except for the right to obtain information regarding the processing of your personal data) to the following email address: Moscow@kkmp.legal.

If you wish to obtain information regarding the processing of your personal data, then pursuant to Part 3 of Article 14 of the Personal Data Law, your request must be sent in electronic or written form and must contain:

the number of your primary identification document or that of your representative;
information on the date of issuance of said document and the authority that issued it;
information confirming the fact of your interaction with us or with our Website;
your signature or the signature of your representative (if the request is submitted in electronic form, it must be signed with an electronic signature rather than a handwritten one).

If you contact us through your representative, we are required to verify the representative's identity and confirm their authority.

V. Transfer of Personal Data

We do not transfer your personal data to third parties without necessity. However, in cases necessary to achieve the purposes of processing, we may transfer data to third parties with your consent or on other grounds provided for by law. Such third parties may include, for example, our contractors who provide hosting and information system support services.

We may also transfer your personal data in other cases provided for by law, for example, to state authorities when they exercise their powers.

VI. Security of Personal Data

The personal data we process is confidential information. To ensure the security of personal data, we have:

appointed a person responsible for the processing of personal data;
developed and adopted internal documents regarding personal data processing matters;
carry out internal control over the compliance of personal data processing;
use only secure databases;
assess the effectiveness of the measures taken;
provide, when interacting with contractors, a set of measures aimed at protecting confidential information;
use modern technical means and software systems, and adopt organizational measures to protect personal data from unauthorized access, unlawful processing or transfer, as well as from loss, distortion, or destruction;
always verify the sufficiency of measures before creating new personal data processing operations;
establish rules for access to personal data, minimizing access and granting it only when strictly necessary, and, where possible, log actions performed with data in information systems;
assess the effectiveness and regularly review the measures taken;
do everything possible to identify vulnerabilities and personal data security incidents;
train our employees on the rules and principles of data processing and information protection, the provisions of the legislation of the Russian Federation, the requirements for non-automated processing, and familiarize them with internal documents.

VII. Processing of Personal Data of Minors

Use of the Website is not intended for minors. We do not process the personal data of minors. We will cease processing personal data if we establish the fact that we have received personal data of a minor.

VIII. Changes to the Policy

This Policy may be amended. The current text of the Policy is available at: https://kkmp.legal. We will notify you of changes to the Policy on the Website.