2. This Policy

We are committed to safeguarding your privacy and Personal Data. In most instances, except when providing data room or e-discovery services to our clients—where our role is confined to that of a data processor—we will be the controller of the Personal Data provided to or collected by us.

This Policy is issued by us to explain: (a) what Personal Data we Process when you visit or use the Site or transmit your Personal Data to the Controller's Email Address; (b) how and why we Process your Personal Data; and (c) what measures we have implemented to safeguard your Personal Data. This Policy does not apply to any third-party website or the contents of any third-party website hyperlinked from the Site. We shall have no liability to any entity for the content or use of the content available through such hyperlinks.

By visiting or using the Site or transmitting your Personal Data to the Controller's Email Address, you acknowledge that you have carefully read this Policy, fully and unconditionally accept it, without any exceptions or reservations, and agree that we may Process your Personal Data. If you do not accept this Policy, please leave the Site immediately and refrain from providing your Personal Data to us.

We reserve the right, at our sole discretion, to modify, alter, or otherwise update this Policy to reflect changes in our practices and procedures concerning the Processing of your Personal Data or amendments in Personal Data Laws. We encourage you to regularly check this page for updates. The revised version of this Policy becomes effective upon publication on this page.


3. Why Do We Process Your Personal Data?

We may Process your Personal Data: (a) to process your requests, establish and maintain contact with you, and provide the information or services you have requested; (b) to conduct pre-engagement assessments and formalities, including conflict checks, "know your client" checks, and anti-money laundering checks; (c) to carry out tasks entrusted to us by our clients and fulfill our client engagements; (d) for internal administrative or operational processes; (e) to ensure the security and successful navigation of the Site, as well as to compile statistical data on its usage; (f) to keep our contact database accurate and up-to-date; (g) to analyze and manage our client relationships; (h) to analyze services that may be of interest to you, including through inquiries and statistical surveys, send invitations and information regarding our events, publications, and services, document events and activities, and publicize events and activities, including on the Site, as part of future invitations and within recruitment publications (if you have agreed to receive our newsletters); (i) to satisfy legal, regulatory, accounting, accreditation, or reporting requirements; and (j) to enter into and perform a contract, where we act as a beneficiary.

We will not Process Personal Data that is inadequate, irrelevant, and exceeds what is necessary in relation to the purposes above.


4. What Personal Data Do We Process?

Our information systems Process the Personal Data of Users as follows:

5. Lawful Basis and Your Consent

We assume that the Personal Data provided by you, irrespective of the method, is accurate and pertains to you, and that you are fully competent and capable of managing your own affairs. In the event of incapacity, your legal representative may share your Personal Data with us.

We Process your Personal Data based on: (a) Personal Data Laws; (b) our internal regulations; and (c) your consent to our Processing of your Personal Data.

You acknowledge that you consent voluntarily, of your own free will, and in your own interest. You also acknowledge that your consent is specific, informed, conscious, and unambiguous.

You have consented to our Processing of your Personal Data when: (a) you have clicked "Accept All" or "Confirm" in the Cookies pop-up window (when visiting the Site); (b) you have clicked "OK" and sent an email communication containing your Personal Data to the Controller's Email Address (when sending us an email communication via the Site). Upon receipt, we will Process only the Personal Data specified in paragraph 4 above. We will not Process and will immediately destroy any Personal Data exceeding this limit; and/or (c) you have checked the checkbox next to the phrase "I have read the following disclaimer" and clicked "SUBMIT" (when filling out the Contact Us or Supplier Inquiry forms on the Site).

In certain cases, we will not require your consent.

If you send us requests or accompanying documents via the Site containing third-party Personal Data, you represent that you are authorized to transmit such Personal Data. Please note that we do not independently verify whether you are but may request confirmation at any time, and you agree to provide it immediately. You shall be liable for the Processing of Personal Data as part of the documents provided without a proper lawful basis. We shall not be liable for the Processing of Personal Data transmitted by you without a proper lawful basis. You undertake to indemnify us for damages caused in case you violate the provisions of this paragraph.


6. How Do We Process Your Personal Data?

We commence the Processing of your Personal Data when you submit it via the Site or transmit it to the Controller's Email Address, and we cease this process when one of the conditions below occurs.

The Processing of your Personal Data will not surpass the period necessary to achieve its purpose and will not extend beyond five years unless further action is required. Processed Personal Data will be destroyed when at least one of the following conditions is met: (a) the Processing purpose has been fulfilled; (b) you have revoked your consent (unless we are compelled to retain your Personal Data by law); (c) you request that we cease Processing your Personal Data; (d) your consent has expired; (e) unauthorized Processing of your Personal Data has been detected, or your Personal Data is inconsistent, etc. with the Processing purpose; (f) we have ceased support of the Site; or (g) we have ceased our operations.


7. What Measures Have We Taken to Protect Your Personal Data?

We have implemented comprehensive legal, technical, and organizational security measures to safeguard your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. These measures include: (a) internal regulations outlining our privacy and Personal Data Processing practices and procedures aimed at identifying and preventing violations of Personal Data Laws, as well as addressing the consequences of such violations; (b) controls preventing any Personal Data Processing that does not meet the requirements of Personal Data Laws and our internal regulations; (c) appointment of a data protection officer; (d) restricting access of our staff to your Personal Data and supporting a permissions-based system of access to it; (e) training our staff directly engaged in the Processing of Personal Data regarding Personal Data Laws and our internal regulations; (f) cataloging media containing Personal Data; (g) restricting access of other persons to our property and premises where we manage Personal Data; (h) utilizing information protection means to neutralize threats that have passed our conformity assessment procedures; (i) detecting malware (through the use of anti-virus software) on all our network nodes; (j) monitoring intrusions into our information systems that violate or threaten our practices and procedures; (k) regularly monitoring the actions of our staff involved in the Processing of your Personal Data and investigating violations of our practices and procedures; and (l) applying other legal, organizational, and technical security measures to ensure the security of your privacy and Personal Data.

In accordance with Article 18(5) of the Personal Data Law, we store your Personal Data in a private and protected cloud located within the Russian Federation and hosted by a third-party service provider.


8. What Are Your Rights?

You have the right to: (a) request access to your Personal Data, and we will confirm to you whether we are Processing your Personal Data and for what purposes, as well as provide details of the categories of Personal Data concerned, the specific pieces of Personal Data concerned, the recipients of the Personal Data, the retention periods (where possible), and your related rights; (b) if any of your Personal Data that we hold appears to be inaccurate or incomplete, ask us to correct or complete it; (c) have your Personal Data erased if it is no longer necessary for us to keep it in connection with the purposes for which it was collected or if the Processing of such Personal Data is otherwise unlawful. However, we will keep track of certain information in order to comply with our legal obligations and/or to handle any claims or litigation; (d) limit the way in which we Process your Personal Data (including requiring us to continue to store your Personal Data but not to otherwise Process it without your consent), for example, where you think the Personal Data we hold is inaccurate, for a period enabling us to verify its accuracy, or where you have objected to the Processing; (e) object to our Processing of your Personal Data on grounds relating to your specific situation, where we are Processing your Personal Data to pursue our legitimate interests; (f) ask us to send you your Personal Data in an electronic, structured, commonly-used, and machine-readable format and have your Personal Data transmitted directly from us to another data controller, where technically feasible without hindrance in case the Processing is carried out by automated means and is based on your consent or is necessary for the performance of a contract to which you are party; (g) withdraw your consent, where the Processing is based on your consent. Withdrawal of consent does not affect the lawfulness of Processing based on consent before it was withdrawn; (h) contact us if you wish to complain about our Processing of your Personal Data, and you may lodge a complaint with the relevant supervisory authority; (i) receive non-discriminatory treatment by us for the exercise of your privacy rights; and (j) have us remove you from our marketing distribution lists. If you currently receive marketing information from us that you would prefer not to receive in the future, please email us at postmaster@grinberg.legal. Personal Data Laws may provide you with other rights.

You may send us requests and other communications via pre-paid first-class post, airmail post, or mail delivery service, providing proof of delivery to the address specified in paragraph 1 above or via email to the email address also specified in paragraph 1 above.


9. We Have Received Your Communication. What's Next?