Privacy Policy for Personal Data Processing

1. General Provisions

This Privacy Policy for Personal Data Processing has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by the Operator to ensure the security of personal data (the “Operator”).

1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of privacy and personal and family confidentiality, to be its highest priority and an essential condition of its operations.

1.2. This Privacy Policy of the Operator regarding personal data processing (the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://bba.expert.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of personal data processing, except where such processing is required to clarify the personal data.

2.3. Website means a collection of graphical and informational materials, as well as software and databases, made available on the Internet at https://bba.expert.

2.4. Personal data information system means a set of personal data contained in databases, together with the information technologies and technical means used to process such data.

2.5. Depersonalization of personal data means actions that make it impossible to determine, without additional information, whether personal data belongs to a specific User or another personal data subject.

2.6. Processing of personal data means any action or set of actions performed with personal data, whether by automated means or without such means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, and determines the purposes of such processing, the scope of personal data to be processed, and the actions performed with personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://bba.expert.

2.9. Personal data permitted by the personal data subject for distribution means personal data to which an unlimited number of persons have been granted access by the personal data subject through consent for the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law.

2.10. User means any visitor to the website https://bba.expert.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data means any actions aimed at disclosing personal data to an undefined group of persons or making personal data available to an unlimited group of persons, including publication in mass media, placement in information and telecommunication networks, or provision of access by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of such data in the personal data information system and/or resulting in the destruction of physical media containing personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

  • receive accurate information and/or documents containing personal data from the personal data subject;
  • continue processing personal data without the consent of the personal data subject in cases where the subject withdraws consent or submits a request to cease processing, provided there are grounds established by the Personal Data Law;
  • independently determine the composition and list of measures necessary and sufficient to fulfill the obligations established by the Personal Data Law and related regulations, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

  • provide the personal data subject, upon request, with information relating to the processing of their personal data;
  • organize personal data processing in accordance with the procedure established by applicable Russian law;
  • respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
  • provide the authorized personal data protection authority with the necessary information within 10 days of receiving such a request;
  • publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
  • take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions;
  • cease the transfer, provision, access, processing, and destruction of personal data in cases provided for by the Personal Data Law;
  • perform other obligations established by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

  • receive information concerning the processing of their personal data, except in cases established by federal laws. Such information shall be provided in an accessible form and must not contain personal data relating to other personal data subjects, unless there are lawful grounds for such disclosure;
  • demand clarification, blocking, or destruction of their personal data if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
  • require prior consent for the processing of personal data for the purpose of promoting goods, works, or services on the market;
  • withdraw consent to personal data processing and submit a request to cease personal data processing;
  • appeal unlawful actions or omissions of the Operator in relation to personal data processing to the authorized personal data protection authority or in court;
  • exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

  • provide the Operator with accurate data about themselves;
  • inform the Operator of clarifications or updates to their personal data.

4.3. Persons who provide the Operator with false information about themselves or about another personal data subject without the subject’s consent bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed lawfully and fairly.

5.2. The processing of personal data shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing incompatible with the purposes of collection is not permitted.

5.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.

5.4. Only personal data that is relevant to the purposes of processing shall be processed.

5.5. The scope and content of processed personal data shall correspond to the stated purposes of processing. Excessive processing in relation to the stated purposes is not permitted.

5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that permits identification of the personal data subject for no longer than is required for the purposes of personal data processing, unless a storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or if such purposes no longer need to be achieved, unless otherwise provided by federal law.

6. Purpose of Personal Data Processing

The purpose of processing User personal data is to inform the User by sending emails and to provide access to services, information, and/or materials available on the website.

The Operator is also entitled to send the User notifications about new products and services, special offers, and various events. The User may opt out of such informational messages at any time by sending an email to contact@bba.expert with the subject line “Opt-out of informational notifications.”

Depersonalized User data collected through internet analytics services is used to gather information about User actions on the website, improve the quality of the website, and enhance its content.

7. Legal Grounds for Personal Data Processing

7.1. The legal grounds for the processing of personal data by the Operator are:

  • the Operator’s statutory and internal documents;
  • contracts concluded between the Operator and the personal data subject;
  • federal laws and other regulatory legal acts governing personal data processing;
  • the personal data subject’s consent to the processing of personal data and to the processing of personal data permitted for distribution.

7.2. The Operator processes personal data only when the data subject independently fills in and/or submits such data through forms available on the website https://bba.expert or sends it to the Operator by email. By filling out the relevant forms and/or sending personal data to the Operator, the User expresses consent to this Policy.

7.3. The Operator processes depersonalized User data if this is permitted by the User’s browser settings (for example, if cookies are enabled and JavaScript is used).

7.4. The personal data subject independently decides whether to provide personal data and does so freely, of their own will, and in their own interest.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with applicable personal data protection laws.

8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except where required by applicable law or where the personal data subject has given consent to such transfer for the performance of obligations under a civil-law contract.

8.3. If inaccuracies in personal data are identified, the User may update the data independently by sending a notification to the Operator at contact@bba.expert with the subject line “Personal Data Update.”

8.4. 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 established by contract or applicable law.

The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator by email to contact@bba.expert with the subject line “Withdrawal of Consent to Personal Data Processing.”

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those persons (Operators) in accordance with their respective Terms of Use and Privacy Policies. The personal data subject and/or User is responsible for independently reviewing such documents in a timely manner. The Operator shall not be liable for the actions of third parties, including the service providers referred to in this paragraph.

8.6. Restrictions established by the personal data subject on the transfer (except access), processing, or conditions of processing of personal data permitted for distribution shall not apply where personal data is processed in the public, state, or other public interest as defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data in the course of personal data processing.

8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than is required by the purposes of personal data processing, unless the storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.

8.9. The grounds for termination of personal data processing may include the achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, a request to cease processing, or identification of unlawful processing of personal data.

9. Actions Performed by the Operator with Received Personal Data

9.1. The Operator performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.

9.2. The Operator carries out automated processing of personal data with or without receiving and/or transferring the information obtained through information and telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Before starting any cross-border transfer of personal data, the Operator shall notify the authorized authority for the protection of personal data subjects of its intention to carry out such transfer. Such notice shall be submitted separately from the notice of intention to process personal data.

10.2. Before submitting the notice specified above, the Operator shall obtain the necessary information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the personal data is intended to be transferred.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications regarding questions related to the processing of their personal data by contacting the Operator by email at contact@bba.expert.

12.2. Any changes to the personal data processing policy adopted by the Operator will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available on the Internet at https://bba.expert/privacy.

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