Operator
Contact details of the data controller
- Operator
- Kovalev & Partners LLC
- OGRN
- 5157746161392
- INN
- 7729486222
- Address
- 6 Michurinsky Prospekt, bldg 3, office 748, Moscow 119607, Russia
- info (at) kovalev.moscow
- Telephone
- +7 499 460-63-47
DOCUMENT
Personal Data Processing Policy
This is an English translation of the Personal Data Processing Policy of Kovalev & Partners LLC, provided for the convenience of English-speaking visitors. In case of any discrepancy, the Russian version prevails.
The Policy of Kovalev & Partners LLC on the processing of personal data. Version 1.0 of 1 January 2026.
1. General provisions
1.1. This Policy sets out how personal data is processed and protected at Kovalev & Partners LLC (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 kovalev.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: Obshchestvo s ogranichennoy otvetstvennostyu «Kovalev i partnery» (Kovalev & Partners LLC).
OGRN 5157746161392, INN 7729486222.
Address: 6 Michurinsky Prospekt, bldg 3, office 748, Moscow 119607, Russia.
Telephone: +7 499 460-63-47. E-mail: info (at) kovalev.moscow.
The person responsible for organising the processing of personal data (art. 22.1 of the Law) is Vladimir Kovalev, managing partner. The responsible person's e-mail address: info (at) kovalev.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 agreement for the provision of legal services, 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
| Purpose | Legal ground |
|---|---|
| Considering an enquiry sent through the site and contacting the sender | Consent of the data subject (art. 6(1)(1) of the Law) |
| Concluding and performing an agreement for the provision of legal services | Art. 6(1)(5) of the Law |
| Keeping accounting and tax records and complying with statutory obligations | Art. 6(1)(2) of the Law |
| Sending informational and marketing messages | Consent 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 statistics | Art. 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) kovalev.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.
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) kovalev.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) kovalev.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.
11. Consent to the processing of personal data
11.1. By submitting a form on the kovalev.moscow website, a visitor gives the Operator consent to the processing of personal data within the meaning of art. 9(1) of the Law. The full text of that consent — its subject matter, purposes, the data and operations covered, its term and how it is withdrawn — is a separate document and is permanently available on its own page.
Read the full consent to the processing of personal data
11.2. Consent is given by ticking the box “I give my consent to the processing of my personal data”. The box is not pre-ticked, and the form cannot be submitted without it. Consent to receive informational and marketing messages is given by a separate tick and has no bearing on how an enquiry is handled.
11.3. Consent may be withdrawn at any time in the manner described in clause 9.4 of this Policy and in the text of the consent itself.