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DOCUMENT

Personal Data Processing Policy

This is an English translation of the Personal Data Processing Policy of the Kovalev, Malyutov, Tsypkalo & Partners Moscow Bar Association, provided for the convenience of English-speaking visitors. In case of any discrepancy, the Russian version prevails.

The Policy of the Kovalev, Malyutov, Tsypkalo & Partners Moscow Bar Association on the processing of personal data. Version 1.0 of 1 September 2026.

1. General provisions

1.1. This Policy sets out how personal data is processed and protected at the Kovalev, Malyutov, Tsypkalo & Partners Moscow Bar Association (the “Operator”) and has been adopted pursuant to art. 18.1(2) of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Law”).

1.2. The Policy applies to all personal data received by the Operator from visitors to the mka.moscow website, clients, counterparties and other persons.

1.3. The current version of the Policy is permanently available on this page.

1.4. Terms are used in the meanings given in art. 3 of the Law: personal data, processing, operator, data subject, automated processing, anonymisation, blocking, destruction.

2. Information about the Operator

Full name: Moskovskaya kollegiya advokatov «Kovalev, Malyutov, Tsypkalo i partnery» (the Kovalev, Malyutov, Tsypkalo & Partners Moscow Bar Association).

OGRN 1197700012377, INN 9729287911.

Address: 12 Koshtoyantsa Street, premises 2 / room 1, Moscow 119454, Russia.

Telephone: +7 499 460-64-27. E-mail: info (at) mka.moscow.

The person responsible for organising the processing of personal data (art. 22.1 of the Law) is Dmitry Malyutov, chairman of the bar association. The responsible person's e-mail address: info (at) mka.moscow.

3. Categories of data subjects and the data processed

3.1. Website visitors who send an enquiry: surname, first name and patronymic or given name; telephone number; e-mail address; the content of the enquiry; the date and time of the enquiry; IP address, browser and device data.

3.1.1. Together with an enquiry sent through a form on the site, the Operator receives and stores technical information about the connection and the visit: the IP address and the country, region, city and internet service provider determined from it; the type, version and language of the browser; the operating system and device type; the screen resolution; the address of the page from which the enquiry was sent and the address of the page on which the visit began; the referring address; advertising and tracking parameters in the page address (utm_source, utm_medium, utm_campaign, utm_term, utm_content, yclid, gclid and similar); the number of pages viewed and the duration of the visit; the date of the first visit to the site; and the visitor identifier in the web analytics system (clause 7.2 of this Policy).

3.1.2. The information listed in clause 3.1.1 is processed in order to consider the enquiry and contact the sender, to establish the source of the enquiry and to keep the site operational and secure, including protecting forms against automated submissions. It is not used on its own, apart from an enquiry received, to identify a visitor.

3.2. Clients and their representatives: the information required to conclude and perform an legal-assistance agreement or other agreement, including passport details, address of registration, information about assets and liabilities and bank details — to the extent provided for by the agreement and by law.

3.3. Counterparties and their representatives: surname, first name and patronymic, position, business contact details, details of the power of attorney.

3.4. Employees and job applicants — to the extent provided for by employment legislation.

3.5. The Operator does not process biometric personal data. Special categories of personal data (art. 10 of the Law) are processed only where they are provided voluntarily by the data subject in connection with the provision of legal services and on the basis of written consent or another ground provided for by art. 10(2) of the Law.

3.6. The Operator does not process the personal data of minors without the consent of their legal representatives.

4. Purposes and legal grounds of processing

PurposeLegal ground
Considering an enquiry sent through the site and contacting the senderConsent of the data subject (art. 6(1)(1) of the Law)
Concluding and performing an legal-assistance agreement or other agreementArt. 6(1)(5) of the Law
Keeping accounting and tax records and complying with statutory obligationsArt. 6(1)(2) of the Law
Sending informational and marketing messagesConsent of the data subject (art. 6(1)(1) of the Law; art. 18(1) of the Federal Law “On Advertising”)
Keeping the site working and secure and collecting anonymised traffic statisticsArt. 6(1)(1) of the Law (consent) and art. 6(1)(7) of the Law (legitimate interest)

5. Procedure, conditions and periods of processing

5.1. Processing is carried out by mixed means: both with and without the use of automation.

5.2. Processing follows the principles set out in art. 5 of the Law: lawfulness and fairness of the purposes, the prohibition on combining databases with incompatible purposes, correspondence between the volume of data and the stated purposes, and the accuracy and sufficiency of the data.

5.3. Databases containing the personal data of citizens of the Russian Federation are located in the territory of the Russian Federation (art. 18(5) of the Law). The Operator does not carry out cross-border transfers of personal data.

5.4. Retention periods: enquiries sent through the website — 3 years from the date of the enquiry or until consent is withdrawn; data processed in connection with the performance of an agreement — for the term of the agreement and 5 years after it ends; data processed for the purpose of sending marketing messages — until consent is withdrawn.

5.5. Once the purpose of processing has been achieved, upon withdrawal of consent or at the request of the data subject, personal data is destroyed within the periods set by art. 21 of the Law.

6. Transfer to third parties

6.1. The Operator does not sell personal data and does not transfer it to third parties for their own purposes.

6.2. Processing may be entrusted, under an agreement containing confidentiality and security obligations (art. 6(3) of the Law), to the following categories of person: the website hosting provider; the operator of the customer relationship management system; the operator of the corporate e-mail service; the telephony operator; the operator of the web analytics service. An up-to-date list is provided on request sent to info (at) mka.moscow.

6.3. Where resolving the data subject's issue requires the involvement of an advocate, the subject's contact details are, with separate consent, passed to an advocate of the Kovalev, Malyutov, Tsypkalo & Partners Moscow Bar Association. Information given by the subject to the advocate is covered by advocate–client privilege (art. 8 of Federal Law No. 63-FZ of 31 May 2002 “On Advocacy and the Bar in the Russian Federation”).

6.4. Personal data is provided to state authorities in the cases and to the extent provided for by law.

7. Cookies and web analytics

7.1. Cookies are small text files saved by the visitor's browser. The Operator uses strictly necessary cookies, which keep the site working, remember the visitor's choices and protect the forms, and analytics cookies, which are set only after the visitor's consent has been obtained.

7.2. Analytics cookies are used by the Yandex Metrica web analytics service (YANDEX LLC, Russia), including its Webvisor technology, to collect traffic statistics and analyse visitor behaviour. Input into form fields is masked during recording and is not stored.

7.3. Where cookies and other identifiers make it possible to identify a particular person directly or indirectly, the Operator treats them as personal data and processes them in accordance with this Policy.

7.4. A visitor may change a decision about optional cookies at any time by pressing the “Cookie settings” button at the foot of the site: the banner opens again and the choice can be switched from “Accept all” to “Necessary only” and back. Stored cookies can also be deleted, and their use prevented, through the browser settings.

7.5. The categories of cookie this site uses, and what each of them does, are set out below.

CategoryWhat it doesConsent needed
Strictly necessaryKeep the site working: they remember the appearance theme you chose and your answer to this very banner, and they protect the enquiry form against automated submissions. Switch them off and the site stops behaving as intended.No — the service is not technically possible without them
AnalyticsSet by the Yandex Metrica service (cookies named _ym…). They count how many people arrive, which sections they read and where they leave the page. These anonymised summaries tell us which materials are useful and which need rewriting. Input into form fields is not recorded.Yes — set only after “Accept all” is pressed
Advertising and profilingNot used. We show no advertising on the site, build no advertising profiles of visitors and pass no data to advertising networks.Not applicable

8. Security measures

8.1. The Operator takes the legal, organisational and technical measures provided for by arts. 18.1 and 19 of the Law, including: appointing a person responsible for organising the processing of personal data; adopting internal regulations on processing; familiarising employees with the requirements of the legislation; identifying security threats and applying measures appropriate to the established protection level; restricting access to personal data; keeping records of machine media; detecting unauthorised access and restoring data; and monitoring the measures taken.

8.2. Data is transmitted between the visitor's browser and the site over the secure HTTPS protocol.

8.3. In the event of an unlawful transfer of personal data, the Operator notifies Roskomnadzor within 24 hours of the incident and within 72 hours of the results of its internal investigation (art. 21(3.1) of the Law).

9. Rights of the data subject

9.1. The data subject has the right to: obtain information concerning the processing of his or her personal data (art. 14 of the Law); require the personal data to be rectified, blocked or destroyed where it is incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the stated purpose; withdraw consent to processing; object to processing for the purposes of promoting services; and complain about the Operator's actions to Roskomnadzor or to a court (art. 17 of the Law).

9.2. Requests are to be sent to info (at) mka.moscow or to the Operator's postal address. A request must contain the information specified in art. 14(3) of the Law.

9.3. A reply is provided within 10 working days of receipt of the request; the period may be extended by no more than 5 working days, with notice to the data subject (art. 20(1) of the Law).

9.4. Withdrawal of consent may be sent in free form to info (at) mka.moscow, stating the surname, first name and the contact details used when making the enquiry, together with the requirement that processing cease.

10. Final provisions

10.1. The Operator may amend this Policy. A new version takes effect from the moment it is published on the site, unless the version itself provides otherwise.

10.2. Previous versions are retained by the Operator and provided on request.

Operator

Contact details of the data controller

Operator
the Kovalev, Malyutov, Tsypkalo & Partners Moscow Bar Association
OGRN
1197700012377
INN
9729287911
Address
12 Koshtoyantsa Street, premises 2 / room 1, Moscow 119454, Russia