Personal Data Processing Policy
This Personal Data Processing Policy (hereinafter referred to as the “Policy”) explains the purposes, content, and procedures for processing personal data, measures aimed at protecting personal data, as well as procedures aimed at identifying and preventing violations of the legislation of the Russian Federation in the field of personal data, and is addressed to all persons whose personal data, as defined under Russian personal data law, may be obtained by Ermolina & Partners LLC (hereinafter referred to as “Ermolina & Partners”) in the process of:
· such persons using the Ermolina & Partners website – https://ermolinapartners.com/ (hereinafter referred to as the “Website”) or other interaction, as a result of which Ermolina & Partners may receive information containing personal data, including through interactive (dialog) software components on the pages of the Website used for integration with information systems and providing Website users with certain opportunities to access information on the Website
· the use by such persons of the pages (channels) of Ermolina & Partners on social networks and messengers managed by Ermolina & Partners (hereinafter referred to as the “Resources”) on the Internet.
This Policy has been drafted in accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter referred to as the “PD Law”), as well as other regulatory and legal acts defining the requirements in the field of personal data processing in accordance with the PD Law.
I.Terms Used in this Policy:
· such persons using the Ermolina & Partners website – https://ermolinapartners.com/ (hereinafter referred to as the “Website”) or other interaction, as a result of which Ermolina & Partners may receive information containing personal data, including through interactive (dialog) software components on the pages of the Website used for integration with information systems and providing Website users with certain opportunities to access information on the Website
· the use by such persons of the pages (channels) of Ermolina & Partners on social networks and messengers managed by Ermolina & Partners (hereinafter referred to as the “Resources”) on the Internet.
This Policy has been drafted in accordance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 (hereinafter referred to as the “PD Law”), as well as other regulatory and legal acts defining the requirements in the field of personal data processing in accordance with the PD Law.
I.Terms Used in this Policy:
Automated personal data processing
processing personal data by means of computer technology
Blocking of personal data
temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data)
Access to personal data
the possibility of obtaining personal data and using it
Ermolina & Partners
Limited Liability Company “Ermolina and Partners” (OGRN: 1247700026848, INN: 9704233199, address: 119034, Moscow, internal territory of the municipal district of Khamovniki, 6 Khilkov Lane)
PD Law
Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006
Информационная система персональных данных
совокупность содержащихся в базах данных персональных данных и обеспечивающих их обработку информационных технологий и технических средств
Anonymization of personal data
actions that make it impossible to determine the ownership of personal data by a specific data subject without using additional information
Processing of personal data
any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data
Operator
a state body, municipal body, legal entity, or individual who, independently or jointly with others, organizes and/or processes personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data
For the purposes of this Policy, Ermolina & Partners is the personal data controller (operator), i.e., it processes personal data and determines the purposes of its processing, the composition of the data, and the actions performed with the personal data.
For the purposes of this Policy, Ermolina & Partners is the personal data controller (operator), i.e., it processes personal data and determines the purposes of its processing, the composition of the data, and the actions performed with the personal data.
Distribution of personal data
actions aimed at disclosing personal data to an indefinite group of persons
Resource
pages (channels) on social networks and messengers, programs, services, and other products on the Internet provided by Ermolina & Partners
Personal data
any information relating directly or indirectly to a specific or identifiable natural person (subject of personal data), or more precisely, a user of the Website or Resource, which may directly or indirectly identify such user (in particular, surname, first name and patronymic (if any), age, gender, contact and other details (if provided by the user to Ermolina & Partners); personal data may also include other information, including information about IP address, commercial or personal preferences, interests, etc.
User
an individual (subject of personal data) using the Website or Resource who is the subject of personal data within the meaning of the Personal Data Protection Act
Provision of personal data
actions aimed at disclosing personal data to a specific person or a specific group of persons
Website
website on the Internet at the address: https://ermolinapartners.com/
Subject of personal data
an individual to whom personal data relates and who is directly or indirectly identified by such data
Destruction of personal data
actions that make it impossible to restore the content of personal data in the personal data information system, including actions to destroy physical media containing personal data
II. Policy Effect
When users use the Website or Resources, we apply the necessary legal, organizational, and technical measures to protect your personal data and other information provided to Ermolina & Partners in accordance with the PD Law.
This Policy contains information on how Ermolina & Partners collects, processes, stores, and protects personal data in the context of using the Website and Resources. The policy provides information about your rights, our obligations, and the contact details of Ermolina & Partners, which users can use to contact us if they have any questions regarding the processing of personal data.
By using our Website or Resources, you acknowledge and agree to the personal data processing practices described in this Policy. If you do not agree with the terms of this Policy, please stop using the Website and Resources.
This Policy contains information on how Ermolina & Partners collects, processes, stores, and protects personal data in the context of using the Website and Resources. The policy provides information about your rights, our obligations, and the contact details of Ermolina & Partners, which users can use to contact us if they have any questions regarding the processing of personal data.
By using our Website or Resources, you acknowledge and agree to the personal data processing practices described in this Policy. If you do not agree with the terms of this Policy, please stop using the Website and Resources.
III. Categories and List of Personal Data Processed by Ermolina & Partners
Ermolina & Partners collects and processes personal data of the following categories of individuals (data subjects):
1. Representatives of current and potential clients (counterparties) of Ermolina & Partners and other persons to whom Ermolina & Partners addresses marketing information;
2. Candidates for vacant positions, as well as for internships, participants in competitions, seminars, and other events held by Ermolina & Partners, who have filled out Ermolina & Partners questionnaires or surveys, provided their resumes and/or proposals for cooperation, or other documents containing personal data;
3. Representatives of the media, media platforms, information centers, publishing companies, rating and research agencies interacting with Ermolina & Partners;
4. Users of the Website or Resources, both those belonging to and those not belonging to the above categories (hereinafter referred to as “any users of the Website”).
The list of personal data collected and processed by Ermolina & Partners depends on the chosen method of interaction with us – through the Website or Resource, or by directly contacting representatives of Ermolina & Partners. Depending on which category of data subjects a particular user belongs to, the amount of personal data processed may also vary.
This Policy defines exclusively the procedure for processing personal data obtained through the Website or Resources. Ermolina & Partners may collect and process the following categories of personal data during the use of the Websites or Resources by users:
1. Representatives of current and potential clients (counterparties) of Ermolina & Partners and other persons to whom Ermolina & Partners addresses marketing information;
2. Candidates for vacant positions, as well as for internships, participants in competitions, seminars, and other events held by Ermolina & Partners, who have filled out Ermolina & Partners questionnaires or surveys, provided their resumes and/or proposals for cooperation, or other documents containing personal data;
3. Representatives of the media, media platforms, information centers, publishing companies, rating and research agencies interacting with Ermolina & Partners;
4. Users of the Website or Resources, both those belonging to and those not belonging to the above categories (hereinafter referred to as “any users of the Website”).
The list of personal data collected and processed by Ermolina & Partners depends on the chosen method of interaction with us – through the Website or Resource, or by directly contacting representatives of Ermolina & Partners. Depending on which category of data subjects a particular user belongs to, the amount of personal data processed may also vary.
This Policy defines exclusively the procedure for processing personal data obtained through the Website or Resources. Ermolina & Partners may collect and process the following categories of personal data during the use of the Websites or Resources by users:
Перечень обрабатываемых персональных данных
Personal data provided by users themselves, including:
· first name, last name, patronymic (if any);
· email address;
· phone number;
· gender/age;
· education;
· position/place of work;
· avatar.
Personal data provided by users themselves, including:
· first name, last name, patronymic (if any);
· email address;
· phone number;
· gender/age;
· education;
· position/place of work;
· avatar.
- representatives of current and potential clients (counterparties) of Ermolina & Partners and other persons to whom marketing information from Ermolina & Partners is addressed;
- candidates for vacant positions, as well as for internships, participants in competitions, seminars, and other events held by Ermolina & Partners, who have filled out questionnaires or surveys of Ermolina & Partners, provided their CVs or proposals for cooperation, or other documents containing personal data;
- representatives of the media, media platforms, information centers, publishing companies, rating and research agencies that interact with Ermolina & Partners.
Information that may be automatically generated during the use of the Website, Resource, and other Internet platforms not directly controlled by Ermolina & Partners:
- electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser identifier data, user device information, card tokens, hardware and software information, Wi-Fi data);
- date and time of access to the Website and/or Resource;
- information about activity while using the Website and/or Resource (e.g., search history, preferences, information about interactions with other users, files and content stored on Ermolina & Partners' systems);
- other information necessary for processing in accordance with the terms and conditions governing the use of the Website or specific Ermolina and Partners Resources.
- any users of the Website.
IV. Special Categories of Personal Data
Ermolina & Partners does not intentionally collect or process sensitive personal information, such as, in particular, information about racial origin, political views, religious or philosophical beliefs, health, and does not collect or process biometric personal data, etc. (hereinafter referred to as “special categories of personal data”).
However, Ermolina & Partners is permitted to process special categories of personal data in cases where the data subject has given their written consent to the processing of their personal data or in other cases provided for by the Personal Data Protection Law in accordance with the requirements of the Personal Data Protection Law.
Ermolina & Partners is not responsible for the processing of special categories of personal data that have been provided by the data subject voluntarily and without proper legal grounds.
However, Ermolina & Partners is permitted to process special categories of personal data in cases where the data subject has given their written consent to the processing of their personal data or in other cases provided for by the Personal Data Protection Law in accordance with the requirements of the Personal Data Protection Law.
Ermolina & Partners is not responsible for the processing of special categories of personal data that have been provided by the data subject voluntarily and without proper legal grounds.
V. Purposes and Legal Grounds for the Processing of Personal Data by Ermolina & Partners
Ermolina & Partners processes personal data only in cases where one or more of the following legal grounds for such processing exist:
· the data subject has given consent to the processing of their personal data;
· processing is necessary to enter into or perform a contract with the data subject (including where the data subject acts as a beneficiary or guarantor);
· the personal data being processed is subject to publication or mandatory disclosure in accordance with Russian law (for example, publicly available information about the sole executive bodies of organizations, their representatives);
· the processing of personal data is necessary for the performance of duties imposed on Ermolina & Partners by Russian law;
· personal data is processed where it is necessary to pursue the legitimate interests of Ermolina & Partners, provided this does not override the rights or interests of the data subject (for example, when conducting a client (counterparty) check);
· personal data is processed for statistical or other research purposes, provided that the personal data is anonymized (for example, when processing information that may be automatically generated during the use of the Website, Resource, and other Internet platforms).
The processing of personal data for the purpose of promoting services on the market by establishing direct contact with a potential customer (counterparty) using means of communication is carried out by Ermolina & Partners only with the prior consent of the data subject, except in cases established by the legislation of the Russian Federation when the processing of personal data may be carried out without such consent. Ermolina & Partners shall cease processing such personal data immediately at the request of the data subject or upon achievement of the purposes for which the personal data was collected, unless otherwise provided by the agreement with the user or applicable law.
In all cases, Ermolina & Partners processes only personal data that is necessary to achieve one or more of the following purposes:
1. Conclusion and execution of civil law contracts, including for the provision of legal services on the basis of such contracts, responding to requests from existing or potential clients and counterparties, creating reports on services rendered, and executing contracts for the provision of legal services and other related services;
2. Providing access to the Website or Resource, informing about the activities of Ermolina & Partners, changes in legislation and data related to the business activities and services of Ermolina & Partners, including personalization of content and other materials;
3. Receiving messages from Ermolina & Partners by clients (counterparties) or users of the Website or Resource, accepting requests and providing responses to such requests;
4. Making decisions on the suitability of applicants for vacant positions and including them in the personnel reserve, making decisions on arranging internships;
5. Receiving and sending materials on issues related to Ermolina & Partners covered in the media, including on websites on the Internet;
6. Promoting the resources and services of Ermolina & Partners, conducting marketing and advertising campaigns;
7. Conducting statistical and other research on the use of the Website or Resource, improving the quality and usability of the Website or Resource, increasing their effectiveness and supporting their functioning;
8. Participating in the evaluation of law firms and participating in various ratings;
9. Fulfilling the obligations imposed on Ermolina & Partners in accordance with Russian law;
hereinafter collectively referred to as the “Purposes.”
Key principles guiding Ermolina & Partners in the processing of personal data:
· Personal data is processed by Ermolina & Partners on a lawful and fair basis;
· Only personal data that meets the purposes of its processing is subject to processing;
· The content and scope of the personal data processed correspond to the stated Purposes of processing;
· The personal data processed must not be excessive in relation to the stated purposes of its processing;
· When processing personal data, the accuracy, adequacy, and, where necessary, relevance of the personal data in relation to the purposes of processing must be ensured;
· Personal data must be stored in a form that allows the subject of the personal data to be identified for no longer than is necessary for the purposes of processing the personal data, unless the period of storage of personal data is established by federal law or by a contract to which the subject of the personal data is a party, beneficiary, or guarantor;
· Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or in the event that the need to achieve these purposes ceases to exist, unless otherwise provided by federal law;
· Ermolina & Partners shall respond to any questions regarding the processing of personal data of data subjects;
· Ermolina & Partners takes all necessary and possible measures to protect personal data.
Ermolina & Partners does not make decisions that have legal consequences for the data subject or otherwise affect their rights and legitimate interests based solely on automated processing of personal data.
· the data subject has given consent to the processing of their personal data;
· processing is necessary to enter into or perform a contract with the data subject (including where the data subject acts as a beneficiary or guarantor);
· the personal data being processed is subject to publication or mandatory disclosure in accordance with Russian law (for example, publicly available information about the sole executive bodies of organizations, their representatives);
· the processing of personal data is necessary for the performance of duties imposed on Ermolina & Partners by Russian law;
· personal data is processed where it is necessary to pursue the legitimate interests of Ermolina & Partners, provided this does not override the rights or interests of the data subject (for example, when conducting a client (counterparty) check);
· personal data is processed for statistical or other research purposes, provided that the personal data is anonymized (for example, when processing information that may be automatically generated during the use of the Website, Resource, and other Internet platforms).
The processing of personal data for the purpose of promoting services on the market by establishing direct contact with a potential customer (counterparty) using means of communication is carried out by Ermolina & Partners only with the prior consent of the data subject, except in cases established by the legislation of the Russian Federation when the processing of personal data may be carried out without such consent. Ermolina & Partners shall cease processing such personal data immediately at the request of the data subject or upon achievement of the purposes for which the personal data was collected, unless otherwise provided by the agreement with the user or applicable law.
In all cases, Ermolina & Partners processes only personal data that is necessary to achieve one or more of the following purposes:
1. Conclusion and execution of civil law contracts, including for the provision of legal services on the basis of such contracts, responding to requests from existing or potential clients and counterparties, creating reports on services rendered, and executing contracts for the provision of legal services and other related services;
2. Providing access to the Website or Resource, informing about the activities of Ermolina & Partners, changes in legislation and data related to the business activities and services of Ermolina & Partners, including personalization of content and other materials;
3. Receiving messages from Ermolina & Partners by clients (counterparties) or users of the Website or Resource, accepting requests and providing responses to such requests;
4. Making decisions on the suitability of applicants for vacant positions and including them in the personnel reserve, making decisions on arranging internships;
5. Receiving and sending materials on issues related to Ermolina & Partners covered in the media, including on websites on the Internet;
6. Promoting the resources and services of Ermolina & Partners, conducting marketing and advertising campaigns;
7. Conducting statistical and other research on the use of the Website or Resource, improving the quality and usability of the Website or Resource, increasing their effectiveness and supporting their functioning;
8. Participating in the evaluation of law firms and participating in various ratings;
9. Fulfilling the obligations imposed on Ermolina & Partners in accordance with Russian law;
hereinafter collectively referred to as the “Purposes.”
Key principles guiding Ermolina & Partners in the processing of personal data:
· Personal data is processed by Ermolina & Partners on a lawful and fair basis;
· Only personal data that meets the purposes of its processing is subject to processing;
· The content and scope of the personal data processed correspond to the stated Purposes of processing;
· The personal data processed must not be excessive in relation to the stated purposes of its processing;
· When processing personal data, the accuracy, adequacy, and, where necessary, relevance of the personal data in relation to the purposes of processing must be ensured;
· Personal data must be stored in a form that allows the subject of the personal data to be identified for no longer than is necessary for the purposes of processing the personal data, unless the period of storage of personal data is established by federal law or by a contract to which the subject of the personal data is a party, beneficiary, or guarantor;
· Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or in the event that the need to achieve these purposes ceases to exist, unless otherwise provided by federal law;
· Ermolina & Partners shall respond to any questions regarding the processing of personal data of data subjects;
· Ermolina & Partners takes all necessary and possible measures to protect personal data.
Ermolina & Partners does not make decisions that have legal consequences for the data subject or otherwise affect their rights and legitimate interests based solely on automated processing of personal data.
VI. Terms of Use of Cookies
For the above purposes, the Ermolina & Partners website uses cookies (for more information, see the Cookie Policy). By using our Website, you consent to our use of cookies for the purposes described in this Policy and in our Cookie Policy.
You can change the validity period of cookies at any time, as well as prohibit their storage in your browser settings.
You can change the validity period of cookies at any time, as well as prohibit their storage in your browser settings.
VII. Procedure for Processing Personal Data
Ermolina & Partners respects the confidentiality of personal data and undertakes not to disclose to third parties or distribute personal data without the consent of the data subject or other legal grounds provided for by the legislation of the Russian Federation.
When processing personal data, Ermolina & Partners takes or implements the necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data.
The Operator processes personal data in accordance with Russian law in the following ways:
· non-automated processing of personal data;
· automated processing of personal data with or without the transfer of the information received via information and telecommunications networks;
· mixed processing of personal data.
Ermolina & Partners may entrust the processing of personal data to third parties, subject to the consent of the data subject. A person processing personal data on behalf of Ermolina & Partners is obliged to comply with all principles and rules for the processing of personal data established by Russian law, as well as the procedure established by this Policy, and to ensure a level of protection of personal data not lower than that established by this Policy.
When processing personal data, Ermolina & Partners takes or implements the necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data.
The Operator processes personal data in accordance with Russian law in the following ways:
· non-automated processing of personal data;
· automated processing of personal data with or without the transfer of the information received via information and telecommunications networks;
· mixed processing of personal data.
Ermolina & Partners may entrust the processing of personal data to third parties, subject to the consent of the data subject. A person processing personal data on behalf of Ermolina & Partners is obliged to comply with all principles and rules for the processing of personal data established by Russian law, as well as the procedure established by this Policy, and to ensure a level of protection of personal data not lower than that established by this Policy.
VIII. Terms of Personal Data Processing
Ermolina & Partners processes personal data for the period necessary to achieve the purposes of personal data processing established by this Policy, or for another period established by Russian law.
IX. Place of Storage of Personal Data
When collecting personal data of citizens of the Russian Federation, Ermolina & Partners ensures the recording, systematization, storage, clarification (updating, modification), and extraction of personal data of citizens of the Russian Federation using databases located in the Russian Federation.
X. Destruction Procedure
With regard to personal data processed by Ermolina & Partners, a uniform procedure for its destruction is in effect in accordance with Russian law and local regulations of Ermolina & Partners.
Personal data shall be destroyed, in particular, if the purpose of its processing has been achieved, the subject of personal data has withdrawn their consent to its processing (and there are no other grounds for processing such data), or the fact of its unlawful processing has been revealed.
Personal data shall be destroyed, in particular, if the purpose of its processing has been achieved, the subject of personal data has withdrawn their consent to its processing (and there are no other grounds for processing such data), or the fact of its unlawful processing has been revealed.
XI. Rights and Obligations of Data Subjects and Obligations of Ermolina & Partners
In relations with Ermolina & Partners, the data subject has the right to:
· full information regarding the processing of their personal data at Ermolina & Partners, except in cases provided for by Russian law;
· clarification of their personal data, its blocking or destruction in cases where the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
· withdrawal of consent to the processing of personal data - consent may be withdrawn in the following manner: by sending a notification to the email address info@ermolinapartners.com;
· taking measures provided for by law to protect their rights;
· appeal to the authorized body for the protection of the rights of data subjects or in court against unlawful actions or inaction of Ermolina & Partners in the processing of personal data.
At the same time, the data subject is responsible for the legality of the provision, relevance, and accuracy of the personal data provided.
Ermolina & Partners, acting as an operator, is obliged to exercise the rights of data subjects by:
· process personal data exclusively for the Purposes specified in the Policy, in accordance with the procedure established by current Russian law, and take the measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it;
· not to disclose personal data without the user's consent, unless otherwise provided by current Russian law;
· to process personal data in compliance with the principles and rules provided for by the PD Law;
· to organize the protection of personal data in accordance with the requirements of Russian law;
· consider requests from users (their legal representatives) regarding the processing of personal data and provide reasoned responses;
· provide users (their legal representatives) with the opportunity to access their personal data free of charge;
· take measures to clarify, block, or destroy the User's personal data in cases established by the Personal Data Protection Law.
Ermolina & Partners, acting as an operator, reserves the right to:
· independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the PD Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the PD Law;
· entrust the processing of personal data to another person with the consent of the user, unless otherwise provided by federal law, on the basis of a contract concluded with that person, including a state or municipal contract, or by the adoption of a relevant act by a state or municipal authority;
· in the event that the user withdraws their consent to the processing of personal data, continue to process personal data without the user's consent if there are grounds specified in the PD Law;
· obtain reliable information and/or documents containing the user's personal data from the user for the Processing Purposes specified in this Policy;
· full information regarding the processing of their personal data at Ermolina & Partners, except in cases provided for by Russian law;
· clarification of their personal data, its blocking or destruction in cases where the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
· withdrawal of consent to the processing of personal data - consent may be withdrawn in the following manner: by sending a notification to the email address info@ermolinapartners.com;
· taking measures provided for by law to protect their rights;
· appeal to the authorized body for the protection of the rights of data subjects or in court against unlawful actions or inaction of Ermolina & Partners in the processing of personal data.
At the same time, the data subject is responsible for the legality of the provision, relevance, and accuracy of the personal data provided.
Ermolina & Partners, acting as an operator, is obliged to exercise the rights of data subjects by:
· process personal data exclusively for the Purposes specified in the Policy, in accordance with the procedure established by current Russian law, and take the measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it;
· not to disclose personal data without the user's consent, unless otherwise provided by current Russian law;
· to process personal data in compliance with the principles and rules provided for by the PD Law;
· to organize the protection of personal data in accordance with the requirements of Russian law;
· consider requests from users (their legal representatives) regarding the processing of personal data and provide reasoned responses;
· provide users (their legal representatives) with the opportunity to access their personal data free of charge;
· take measures to clarify, block, or destroy the User's personal data in cases established by the Personal Data Protection Law.
Ermolina & Partners, acting as an operator, reserves the right to:
· independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the PD Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the PD Law;
· entrust the processing of personal data to another person with the consent of the user, unless otherwise provided by federal law, on the basis of a contract concluded with that person, including a state or municipal contract, or by the adoption of a relevant act by a state or municipal authority;
· in the event that the user withdraws their consent to the processing of personal data, continue to process personal data without the user's consent if there are grounds specified in the PD Law;
· obtain reliable information and/or documents containing the user's personal data from the user for the Processing Purposes specified in this Policy;
- · require the user to promptly clarify the personal data provided.
XII. Contacts for Data Subjects
Ermolina & Partners welcomes questions and suggestions regarding the implementation or amendment of this Policy. All suggestions or questions regarding the Policy or in connection with the processing of personal data should be sent to the following email address: info@ermolinapartners.com.
Date of Publication: 21.11.2025.
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This Policy may be amended, including in cases where the relevant adjustments are related to changes in applicable law. The new version of the Policy shall come into force from the moment it is posted on the Website, unless otherwise provided by the new version of the Policy. The new version of the Policy shall apply to relations arising after its entry into force.Date of Publication: 21.11.2025.