This Personal Data Processing Policy (the “Policy”) has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law”) and sets out how the Operator processes personal data and the measures it takes to keep that data secure.
1.1. The Operator regards the observance of human and civil rights and freedoms in the processing of personal data — including the right to privacy and to personal and family confidentiality — as its paramount objective.
1.2. This Policy applies to all information the Operator may obtain about visitors to the website https://popov.moscow (the “Website”), and in the course of correspondence and telephone conversations with them.
1.3. This Policy applies to processing carried out both by automated means and otherwise than by automated means.
1.4. The Operator is entered in the Register of Operators processing personal data, maintained by the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor), under registration number 77-25-491473, by Order No. 664 of 29 September 2025. Under Part 4 of Article 22 of the Law the information held in the Register is publicly available. Processing commenced on 25 October 2025.
1.5. The current version of this Policy is freely available at popov.moscow/privacy, providing unrestricted access to it before any processing begins.
2.1. Personal data means any information relating directly or indirectly to an identified or identifiable natural person (the data subject).
2.2. User means a visitor to the Website who has submitted their data through the enquiry form or has otherwise contacted the Operator.
2.3. Processing means any operation or set of operations performed on personal data, whether or not by automated means.
2.4. Other terms — blocking, anonymisation, destruction of personal data, personal data information system and others — have the meanings given to them in Article 3 of the Law.
3.1. Processing is carried out on a lawful and fair basis.
3.2. Processing is limited to the achievement of specific, predetermined and legitimate purposes. Processing incompatible with the purposes of collection is not permitted.
3.3. Databases containing personal data processed for purposes that are incompatible with one another are not combined.
3.4. Only personal data that meets the purposes of processing is processed. Its content and volume are not excessive in relation to those purposes.
3.5. The Operator ensures that personal data is accurate and sufficient and, where necessary, kept up to date for the purposes of processing.
3.6. Personal data is stored in a form permitting identification of the data subject for no longer than the purposes of processing require, unless a retention period is prescribed by law or by contract.
4.1. The Operator processes personal data for the following purposes:
4.2. The Operator does not send marketing or promotional communications and does not use personal data to promote goods, works or services. Nor does it take decisions producing legal effects based solely on automated processing.
4.3. Categories of data subjects: Website visitors, clients, counterparties and their representatives, beneficiaries under contracts, and legal representatives.
4.4. The categories of personal data processed depend on the stage of the relationship.
4.4.1. Where an enquiry is made through the Website, the following are processed: surname, first name and patronymic; telephone number; email address; and the content of the enquiry. The enquiry form requests no other information.
4.4.2. Where an agreement is entered into and performed, the following may additionally be processed: year, month, date and place of birth; residential address and registered address; identity document details, including documents issued outside the Russian Federation; birth certificate details; SNILS (social insurance number); INN (taxpayer number); position held; bank account number and payment card details.
4.4.3. The data referred to in clause 4.4.2 is determined by the nature of the instruction and is not excessive: the Operator requests only such information as is indispensable for providing the particular service.
4.5. The Operator does not process special categories of personal data (racial or ethnic origin, political opinions, religious or philosophical beliefs, health or sex life) or biometric personal data.
4.6. The legal bases for processing are:
4.7. Provision of personal data is voluntary. A refusal to provide it makes it impossible to consider the enquiry or to provide the services.
5.1. Processing comprises the following operations: dissemination, collection, recording, systematisation, accumulation, storage, updating (amendment, alteration), extraction, use, transfer (provision of, and access to, data), anonymisation, blocking, deletion and destruction.
5.2. Processing is carried out by automated means, including transmission over the internet.
5.3. Personal data is transferred to third parties solely to the extent necessary to achieve the purposes in clause 4.1, namely: to courts and other dispute resolution bodies; to state authorities, including the Federal Customs Service, the Federal Service for Intellectual Property (Rospatent), and tax and registration authorities; and to notaries, translators and other persons engaged in carrying out the data subject’s instruction — and otherwise in the cases expressly provided for by the legislation of the Russian Federation.
5.4. Dissemination of personal data, that is disclosure to an indefinite group of persons, takes place only where the data subject has given separate consent in the form prescribed by Article 10.1 of the Law. Without such consent, personal data is not disclosed to an indefinite group of persons.
5.5. The Operator does not carry out cross-border transfers of personal data.
5.6. The recording, systematisation, accumulation, storage, updating and extraction of the personal data of citizens of the Russian Federation are carried out using databases located within the Russian Federation (Article 18(5) of the Law).
5.7. Processing ceases where the purposes of processing have been achieved, consent is withdrawn, unlawful processing is identified, or the Operator ceases to trade.
6.1. Personal data received through the enquiry form is retained for three years from the User’s most recent contact, unless a different period is prescribed by contract or by law.
6.2. Personal data contained in accounting and tax records is retained for the periods prescribed by the legislation of the Russian Federation.
6.3. Once the purposes of processing have been achieved, or the need to achieve them has fallen away, personal data is destroyed. Destruction is recorded in a written act drawn up by the Operator.
7.1. In accordance with Article 18.1 of the Law, the Operator has:
7.2. In accordance with Article 19 of the Law, the Operator has taken legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision or dissemination, and against other unlawful acts, including:
7.3. The Operator does not use cryptographic means of information protection.
7.4. Where the Operator establishes that personal data has been unlawfully transferred and that this has infringed the rights of data subjects, it notifies the supervisory authority in the manner and within the time limits prescribed by Article 21(3.1) of the Law.
8.1. The User has the right:
8.2. The User must provide accurate personal data and inform the Operator promptly of any changes to it.
8.3. Requests should be sent to hello@popov.moscow. The Operator will consider the request and respond within ten working days of receiving it. That period may be extended by no more than five working days, with notice of the reasons for the extension.
9.1. Consent may be withdrawn at any time by sending a written request to hello@popov.moscow marked “Withdrawal of consent”. The request should state the surname, first name, patronymic and telephone number previously provided, as these are needed to identify the data subject.
9.2. Processing will cease and the personal data will be destroyed within thirty days of receipt of the withdrawal, unless there is another legal basis for processing it.
9.3. Where the grounds set out in Article 6(1)(2)–(11), Article 10(2) or Article 11(2) of the Law apply, the Operator may continue to process personal data without the data subject’s consent.
10.1. The Website does not use cookies to identify Users and does not place third-party advertising or tracking identifiers.
10.2. Should web analytics be introduced, the Operator will process anonymised visit data in accordance with this Policy and will amend this Policy accordingly.
11.1. Questions about the processing of personal data may be sent to hello@popov.moscow.
11.2. The Operator may amend this Policy. A new version takes effect once published on the Website, unless the new version provides otherwise.
11.3. This Policy remains in force indefinitely until replaced by a new version.
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