Personal Data Processing Policy

1. General provisions
1.1. This personal data processing policy has been drawn up in accordance with the requirements of Federal Law dd. 27.07.2006 No. 152-FZ "On Personal Data" (the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data taken by JUSTINIAN Law Office, Moscow (the "Operator").
In accordance with Part 2 of Article 18.1 of the Personal Data Law, this Policy shall be published on the Operator’s website in order to ensure unlimited access to it.
1.2. The terms contained in Article 3 of the Personal Data Law are used in this Policy with a similar meaning.
1.3. This Operator's personal data processing policy (the "Policy") applies to all information that the Operator may obtain about Personal Data Subjects.
1.4 The Policy applies to all operations performed by the Operator with personal data with or without the use of automation tools.

2. Basic rights and obligations of the Operator
2.1. The Operator has the right to:
- receive from the Personal Data Subject reliable information and/or documents containing personal data;
- in case the Personal Data Subject revokes their consent to the processing of personal data, as well as if they submit a request to stop the processing of personal data, the Operator has the right to continue the processing of personal data without the consent of the Personal Data Subject if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it unless otherwise provided by the Personal Data Law or other federal laws.
2.2. The Operator is obligated to:
- provide the Personal Data Subject, upon their request, with information regarding the processing of their personal data;
- organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
- respond to appeals and inquiries of the Personal Data Subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- notify the authorized body for the protection of the rights of the Personal Data Subjects, at the request of this body, about the required information within 10 days from the date of receipt of such request;
- publish or otherwise provide unlimited access to this Personal Data Processing Policy;
- take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data;
- cease transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Personal Data Law;
- fulfill other obligations stipulated by the Personal Data Law.

3. Basic rights and obligations of the Personal Data Subjects
3.1. The Personal Data Subjects have the right to:
- receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information shall be provided to the Personal Data Subject by the Operator in an accessible form and shall not contain personal data relating to other Personal Data Subjects unless there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
- request that the Operator clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
- set forth a condition of prior consent when processing personal data for the purpose of promoting goods, works and services in the market;
- revoke consent to the processing of personal data, as well as send a request to stop processing the personal data;
- appeal to the authorized body for the protection of the rights of the Personal Data Subjects or in court against unlawful acts or omissions of the Operator in processing of their personal data;
- exercise other rights provided for by the legislation of the Russian Federation.
3.2. The Personal Data Subjects are obliged to:
- provide the Operator with true data about themselves;
- inform the Operator about clarification (update, change) of their personal data.
3.3. Persons who have provided the Operator with false information about themselves or information about another Personal Data Subject without the latter’s consent shall be held liable in accordance with the legislation of the Russian Federation.

4. Principles of personal data processing
4.1. Processing of personal data is carried out on a lawful and fair basis.
4.2. Personal data processing is limited to the attainment of specific, predetermined and legitimate goals. Personal data processing incompatible with the purposes of personal data collection is not allowed.
4.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
4.4. Only personal data that meets the purposes of its processing is subject to processing.
4.5. Content and volume of the processed personal data correspond to the declared purposes of processing. Redundancy of the processed personal data in relation to the declared purposes of its processing is not allowed.
4.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing shall be ensured. The Operator shall take the necessary measures and/or ensure that the data is taken to remove or refine incomplete or inaccurate data.
4.7. Personal data shall be stored in a form that allows identification of the Personal Data Subject for no longer than required by the purposes of personal data processing unless the period of personal data storage is established by federal law, contract to which the Personal Data Subject is a party or beneficiary. The processed personal data is destroyed or depersonalized upon attainment of the processing goals or in case of loss of the need to achieve these goals unless otherwise provided by a federal law.
4.8. Personal data processing is carried out in compliance with the principles and rules stipulated by Federal Law dd. 27.07.2006 No. 152-FZ "On Personal Data" and the Policy.
4.9 The Operator does not carry out cross-border transfer of personal data.

5. Purposes of personal data processing
5.1. Processing of personal data by the Operator in respect of persons who apply to the Operator for consultation and/or service in the scope of law or any other service is carried out for the following purposes:
- development/updating/testing and (or) technical support of the Operator's information systems and infrastructure, including technical support of the online application on the Operator's website (if any);
- verification of the relevance, completeness and reliability of the information and documents provided;
- informing about the status of the application;
- conclusion of any contracts with the Personal Data Subjects and their further performance;
- provision of the Operator's services and information on the said services to the Personal Data Subjects;
- realization of rights and legitimate interests of the Operator related to participation in constitutional, civil, administrative, criminal proceedings, proceedings in arbitration courts;
- storage and other processing of personal data for the implementation and fulfillment of functions, powers and duties assigned to the Operator by the legislation of the Russian Federation;
- ensuring protection of human and civil rights and freedoms during processing of personal data, including the protection of the rights to privacy, personal and family secrecy;
- provision by the Operator to individuals and legal entities of services related to the Operator's business activities, including the Operator's contacts with such persons as by e-mail, by phone, at the address provided by the respective person;
- sending consultations, answers to the persons who have applied by communication means and contractual data specified by them;
- promotion of the Operator's goods, works, services in the market through direct contacts with potential consumers by communication means (allowed only with the prior consent of the Personal Data Subject).

6. Terms of personal data processing
6.1. Processing of personal data is carried out with the consent of the Personal Data Subject to the processing of their personal data.
6.2. Processing of personal data is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or law, to fulfill the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.
6.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
6.4. Processing of personal data is necessary for the execution of a contract to which the Personal Data Subject is a party or beneficiary, as well as for the conclusion of a contract at the initiative of the Personal Data Subject or a contract under which the Personal Data Subject will be a beneficiary.
6.5. Processing of personal data is necessary for realization of the rights and legitimate interests of the Operator or third parties or for achievement of socially important purposes, provided that the rights and freedoms of the Personal Data Subject are not violated.
6.6. Processing of personal data access to which is granted to an unlimited number of persons is carried out by the Personal Data Subject or at their request.
6.7. Processing of personal data is subject to publication or mandatory disclosure in accordance with federal law.

7. Procedure for collecting, storing, transferring and other types of processing personal data
Security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the area of personal data protection.
7.1. The Operator ensures safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
7.2. The Personal Data Subject's personal data will never, under no circumstances, be transferred to third parties, except in cases related to the execution of the applicable law or if the Personal Data Subject has given their consent to the Operator to transfer the data to a third party for the fulfillment of obligations under a civil law contract.
7.3. In case of identification of inaccuracies in personal data, the Personal Data Subject may update it independently by sending a notice to the Operator to the Operator's e-mail address mail@lbmos.com with the reference "Personal Data Update".
7.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless another period is stipulated by the contract or applicable law.
The Personal Data Subject may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator's e-mail address mail@lbmos.com with the reference "Withdrawal of consent to the processing of personal data".
7.5. All information that is collected by third-party services, including payment systems, communications and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this clause.
7.6. The prohibitions established by the Personal Data Subject on the transfer (other than granting access), as well as on the processing or conditions of processing (other than access) of personal data permitted for dissemination shall not apply in cases of personal data processing in the governmental, public and other community interests defined by the legislation of the Russian Federation.
7.7. When processing personal data, the Operator shall ensure confidentiality of personal data.
7.8. The Operator shall store personal data in a form that allows identification of the Personal Data Subject for no longer than required by the purposes of personal data processing unless the period of personal data storage is established by a federal law, contract to which the Personal Data Subject is a party or beneficiary.
7.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the Personal Data Subject's consent, revocation of consent by the Personal Data Subject or a request to terminate personal data processing, as well as the detection of unlawful processing of personal data.

8. List of actions performed by the Operator with the received personal data
8.1. The Operator shall collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer (disseminate, provide, access), depersonalize, block, delete and destroy personal data.
8.2. The Operator carries out automated and non-automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

10. Confidentiality of personal data
10.1. The Operator and other persons who have access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the Personal Data Subject unless otherwise provided for by federal law.

11. Final provisions
11.1. The Personal Data Subject may obtain any clarifications on the issues of interest regarding the processing of their personal data by contacting the Operator via e-mail at mail@lbmos.com.
11.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is in effect indefinitely until it is replaced by a new version.
11.3. The current version of the Policy is freely available on the Internet at https://lbmos.com.