Victoria Krupina
Русская версия

Privacy Policy

Vladivostok “22” September 2026

1. GENERAL PROVISIONS

1.1. This document (hereinafter referred to as the “Policy”) sets out the policy regarding the processing of personal data of users of the website of Viktoria Valeryevna Krupina (Taxpayer Identification Number (INN) 253600251305) (hereinafter referred to as the “Operator”) in the information and telecommunications network Internet at: https://krupinaconsult.ru (hereinafter referred to as the “Website”).

1.2. This Policy has been developed pursuant to Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (hereinafter referred to as the “Personal Data Law”), as well as the Recommendations for drafting a document establishing the operator’s policy regarding the processing of personal data, in accordance with the procedure established by the Personal Data Law.

1.3. In compliance with the requirements of Part 2, Article 18.1 of the Personal Data Law, this Policy is made publicly available on the Operator’s Website at: https://krupinaconsult.ru.

1.4. This Policy applies only to the Website. The Operator does not control and is not responsible for third-party websites to which the User may navigate via links available on the Website.

1.5. The terms defined in Article 3 of the Personal Data Law are used in this Policy with the same meaning.

1.6. The following terms are also used in this Policy:

User means any person visiting the Website and using the information, materials and services of the Website. A Website user is a personal-data subject within the meaning of the Personal Data Law.

1.7. Rights and obligations of the Operator

1.7.1. The Operator shall:

  • process personal data solely for the purposes specified in this Policy, in accordance with the procedure established by the applicable laws of the Russian Federation, and take the measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and regulatory legal acts adopted pursuant thereto;
  • not disseminate personal data without the User’s consent, unless otherwise provided by the applicable laws of the Russian Federation;
  • process personal data in compliance with the principles and rules established by the Personal Data Law;
  • arrange for the protection of personal data in accordance with the requirements of the laws of the Russian Federation;
  • consider requests from the User or the User’s legal representative concerning the processing of personal data and provide reasoned responses;
  • provide the User or the User’s legal representative with the opportunity to access the User’s personal data free of charge;
  • take measures to rectify, block or destroy the User’s personal data in the cases established by the Personal Data Law.

1.7.2. The Operator shall have the right to:

  • independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Personal Data Law and regulatory legal acts adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws;
  • entrust the processing of personal data to another person with the User’s consent, unless otherwise provided by federal law, on the basis of an agreement concluded with such person, including a state or municipal contract, or by virtue of an act adopted by a state or municipal authority;
  • continue processing personal data without the User’s consent after the User withdraws consent to the processing of personal data, where there are grounds specified in the Personal Data Law.

1.8. Rights and obligations of the User

1.8.1. The User shall:

  • ensure the accuracy of the personal data provided to the Operator that are necessary for the processing purposes specified in Clause 2.2 of this Policy;
  • provide the Operator, where necessary, with information required to clarify, update or amend the personal data provided.

1.8.2. The User shall have the right to:

  • receive complete information concerning the processing of the User’s personal data by the Operator, except in cases provided for by the laws of the Russian Federation;
  • have the User’s personal data clarified, blocked or destroyed where the personal data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing;
  • withdraw consent to the processing of personal data;
  • take statutory measures to protect the User’s rights;
  • challenge unlawful acts or omissions of the Operator in the processing of the User’s personal data before the authorised body for the protection of the rights of personal-data subjects or in court.

The Operator and Users shall also have other rights and bear other obligations provided for by the laws of the Russian Federation.

2. PURPOSES OF PERSONAL-DATA PROCESSING

The Operator processes the User’s personal data for the following purposes:

  • reviewing the User’s requests;
  • providing feedback from the Operator concerning the subject matter of the request;
  • providing legal services;
  • discussing potential cooperation;
  • informing the User of the status of the request;
  • improving the quality of the Website and services.

3. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

3.1. The Operator processes the personal data of Website Users on the basis of Part 1, Article 6 of the Personal Data Law.

3.2. In respect of data collected through the Website, including through the feedback form, by e-mail and with the use of cookies, the legal grounds for processing are as follows:

  • entering into a contract at the initiative of the personal-data subject and/or performance of a contract to which the personal-data subject is a party - Clause 5, Part 1, Article 6 of the Personal Data Law - when processing data provided by the User for the purpose of requesting legal advice, submitting an application for services, sending a request through forms on the Website, and subsequent interaction for the purpose of entering into and performing an agreement for the provision of legal services;
  • consent of the personal-data subject - Clause 1, Part 1, Article 6 of the Personal Data Law - where processing cannot be carried out on the basis of Clause 5, Part 1, Article 6 of the Personal Data Law, including:
    • when certain types of cookies are used for analytics, advertising and marketing purposes;
    • when the User submits requests, if such requests are processed solely on the basis of consent;
  • exercise of the rights and legitimate interests of the Operator, provided that this does not violate the rights and freedoms of the personal-data subject - Clause 7, Part 1, Article 6 of the Personal Data Law - for the purposes of ensuring the security of the Website, preventing fraud and abuse, protecting the rights and legitimate interests of the Operator in disputes and legal proceedings, and conducting internal reporting and audits related to the operation of the Website;
  • compliance with obligations established by the laws of the Russian Federation - Clause 2, Part 1, Article 6 of the Personal Data Law - to the extent necessary to comply with mandatory requirements, including tax and accounting legislation and requirements concerning the retention of certain categories of information, applicable to the Operator’s activities in connection with the operation of the Website and the processing of Users’ data.

3.3. Where the processing of Website Users’ data is based on the consent of the personal-data subject, such consent shall be given voluntarily, specifically and with full information by the User and may be withdrawn by the User at any time in accordance with Section 6 of this Policy.

4. SCOPE AND CATEGORIES OF PROCESSED PERSONAL DATA AND CATEGORIES OF PERSONAL-DATA SUBJECTS

4.1. The Operator may process the personal data of the following Users: visitors to the Operator’s Website.

4.2. The personal data processed by the Operator include:

  • surname, first name and patronymic;
  • e-mail address;
  • telephone number;
  • preferred method of communication;
  • other data provided in the text of the request.

4.3. Cookies may be used to automatically collect other data, including the technical characteristics of the device, IP address, information about the browser used and language settings, the date and time of access to the Website, the addresses of the Website pages requested and other similar information.

For more information, please see the Cookie Processing Policy.

5. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA

5.1. The Operator processes personal data in accordance with the requirements of the laws of the Russian Federation using the following methods:

  • non-automated processing of personal data;
  • automated processing of personal data, with or without transmission of the information received via information and telecommunications networks;
  • mixed processing of personal data.

5.2. The list of actions performed by the Operator with the User’s personal data for the purposes specified in Clause 2.2 of this Policy includes: collection, recording, systematisation, accumulation, storage, clarification, updating, amendment, retrieval, use, transfer in relation to cookies, blocking, deletion and destruction.

5.3. The Operator processes personal data subject to obtaining the User’s consent (hereinafter referred to as the “Consent”), given in accordance with the requirements of the Personal Data Law, except in cases established by the laws of the Russian Federation where personal data may be processed without such Consent.

5.4. The User decides whether to provide personal data and gives the Consent freely, at the User’s own discretion and in the User’s own interests.

5.5. Personal data shall be processed until the purposes for which they were collected have been achieved, unless a different period is established by an agreement with the User or by the applicable laws. In respect of personal data submitted through the feedback form on the Website, the processing period shall be one (1) year.

Processing may be terminated upon achievement of the purposes of processing or loss of the need to achieve such purposes, expiry of the Consent, withdrawal of the Consent by the User, or detection of unlawful processing of personal data.

5.6. Consent may be withdrawn by sending an application to the Operator by e-mail at info@krupinaconsult.ru.

5.7. When processing personal data, the Operator shall take or ensure the taking of the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions in respect of personal data.

6. BLOCKING, CLARIFICATION AND DESTRUCTION OF PERSONAL DATA. RESPONSES TO USERS’ REQUESTS FOR ACCESS TO PERSONAL DATA

6.1. If unlawful processing of personal data is detected following an application by the User or the User’s representative, at the request of the User or the User’s representative, or at the request of the authorised body for the protection of the rights of personal-data subjects, the Operator shall block, or ensure the blocking of, the unlawfully processed personal data relating to the relevant User from the moment of receiving such application or request for the duration of the verification.

If inaccurate personal data are detected following an application by the User or the User’s representative, at their request or at the request of the authorised body for the protection of the rights of personal-data subjects, the Operator shall block, or ensure the blocking of, the personal data relating to the relevant User from the moment of receiving such application or request for the duration of the verification, provided that blocking the personal data does not violate the rights and legitimate interests of the User or third parties.

6.2. If the inaccuracy of personal data is confirmed, the Operator shall, on the basis of information provided by the User or the User’s representative, or by the authorised body for the protection of the rights of personal-data subjects, or on the basis of other necessary documents, clarify the personal data or ensure their clarification within seven business days from the date such information is provided.

6.3. If unlawful processing of personal data is detected, the Operator shall terminate, or ensure the termination of, such unlawful processing within a period not exceeding three business days from the date on which the unlawful processing was detected. If it is impossible to make the processing lawful, the Operator shall destroy, or ensure the destruction of, such personal data within a period not exceeding ten business days from the date on which the unlawful processing was detected.

6.4. Upon achievement of the purpose of processing personal data or expiry of the processing period, the Operator shall destroy, or ensure the destruction of, the personal data within a period not exceeding thirty days from the date on which the purpose of processing was achieved, unless otherwise provided by an agreement to which the User is a party, beneficiary or guarantor, another agreement between the Operator and the User, or where the Operator is entitled to process personal data without the User’s consent on the grounds provided for by the Personal Data Law or other federal laws.

6.5. If the User withdraws consent to the processing of the User’s personal data and retention of the personal data is no longer necessary for the processing purposes, the Operator shall destroy, or ensure the destruction of, the personal data within a period not exceeding thirty days from the date of receipt of such withdrawal, unless otherwise provided by an agreement to which the User is a party, beneficiary or guarantor, another agreement between the Operator and the User, or where the Operator is entitled to process personal data without the User’s consent on the grounds provided for by the Personal Data Law or other federal laws.

6.6. Within a period not exceeding seven business days from the date on which the User or the User’s representative provides information confirming that the personal data were obtained unlawfully or are unnecessary for the stated purpose of processing, the Operator shall destroy such personal data.

6.7. The personal data being processed shall be destroyed if it is no longer necessary to achieve the purposes of processing or if the processing period has expired, unless otherwise provided by federal law.

6.8. The Operator shall respond to requests and applications from the User or the User’s representative concerning the processing of personal data by e-mail at info@krupinaconsult.ru.

7. DISPUTE RESOLUTION

7.1. Any disputes and/or disagreements arising from the relationship between the User and the Operator shall be resolved in accordance with the applicable laws of the Russian Federation.

7.2. This Policy and the relationship between the User and the Operator shall be governed by the applicable laws of the Russian Federation.

8. FINAL PROVISIONS

8.1. The Operator may amend this Policy without the User’s consent.

8.2. A new version of the Policy shall enter into force upon its publication on the Website, unless otherwise provided by the new version of the Policy.

The new version of the Policy shall apply to relationships arising after it enters into force.

8.3. All suggestions or questions concerning this Policy should be sent by e-mail to info@krupinaconsult.ru.