Personal Data Processing Policy
This Personal Data Processing Policy («Policy») has been developed by Trey Legal Limited Liability Company, with its registered office at 34, Bolshaya Cheremushkinskaya Street, Moscow, 117218, Russian Federation, office M316, OGRN 1207700383791, TIN 7727453937 («Trey Legal» or «we») to comprehensively describe our approach to the processing of personal data that we collect and process when you use our website, www.trey.legal (the «Website»).
In processing your personal data in connection with your use of the Website, Trey Legal acts as a personal data controller (as defined below) and is governed by the requirements of the laws and other regulatory legal acts of the Russian Federation in the field of information and personal data protection, notably Federal Act No. 152-FZ dated 27 July 2006 «About Personal Data,» Resolution of the Government of the Russian Federation No. 1119 dated 1 November 2012 «About Approval of Requirements for the Protection of Personal Data when Processing in Information Systems of the Russian Federation.»
1. TERMS USED
Personal Data Operator is a legal entity that independently or jointly with other individuals organizes and (or) carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data subject to processing, and actions (operations) performed with personal data. The operator of your personal data is Trey Legal.
Personal Data refers to any information directly or indirectly related to a specific or definable natural person (the subject of personal data). The subject of personal data is you, the user of the Website.
Confidentiality of Personal Data is a mandatory requirement for Trey Legal or any other individuals who have access to personal data to refrain from disseminating it without the consent of the subject of personal data or other legal basis.
Processing of Personal Data encompasses any action (operation) or set of actions (operations) performed in relation to personal data, whether with or without the use of automation means. This includes collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
Non-Automated Processing of Personal Data involves any actions with personal data that require direct human involvement in their use, clarification, distribution, and destruction.
Automated Processing of Personal Data is the processing of personal data facilitated by computer equipment.
Destruction of Personal Data involves actions that render it impossible to restore the content of personal data in the information system and/or result in the physical destruction of material carriers of personal data.
Blocking of Personal Data refers to the temporary cessation of personal data processing, except in cases where processing is necessary to clarify personal data.
Personal Data Information System is a collection of personal data stored in databases and the information technologies and technical means that ensure their processing.
Special Categories of Personal Data encompass data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health, and intimate life.
2. WHICH CATEGORIES OF PERSONAL DATA WE PROCESS AND FOR WHAT PURPOSES
You can explore information about Trey Legal, our team, our areas of expertise, the services we offer, and our awards on our Website without providing any personal information about yourself. We will not process your personal data except for information collected automatically (as described in Section 5 of this Policy). We will also refrain from processing your biometric personal data or special categories of personal data.
However, some features on our Website require the processing of your personal data. In such cases, we will only process the data you provide to us, except for data collected automatically (as outlined in Section 5 of this Policy). We will not receive your personal data from third parties, nor will we process such data.
Below, we outline the instances in which we process your personal data in connection with your use of the Website, along with the types of personal data we process and the purposes for which we process them:
2.1 Subscribing to Our Email Newsletter
We continuously monitor changes and trends in legislation and law enforcement practices to keep our current and potential clients informed. To achieve this, our team periodically prepares informational materials (letters).
If you would like to receive such information, you can subscribe to our newsletter in the relevant section of the Website. We will ask for your consent to process your personal data for the purpose of sending you marketing and other informational materials when you subscribe to us and use the Website’s functionality. We will not send you such materials without your express consent.
Furthermore, you can withdraw your consent to the processing of your data for the purpose of receiving marketing and informational materials at any time. If you do so, we will immediately cease the relevant processing. Additionally, we will ensure that each marketing email from us provides you with the option to opt out of receiving future communications.
When you subscribe to the newsletter, Trey Legal collects the following categories of personal data directly from you: e-mail address.
2.2 Sending Us a Request for Counselling
We will request your consent to process your personal data for the purposes of contacting you and providing counselling. We will not direct you to contact us for other matters unless you provide us with your express consent.
We will always respond to your inquiry. To do so, you can direct your request for counselling to us in the relevant section of the Website.
When you subscribe to the newsletter, Trey Legal collects the following categories of personal data directly from you: first name, middle name, last name, e-mail address, telephone number.
3. LAWFUL GROUNDS FOR PROCESSING YOUR PERSONAL DATA
Trey Legal will process personal data only if there are lawful grounds for doing so. In addition to the lawful grounds described in Section 2 of this Policy above, Trey Legal processes your personal data in the following cases:
(A) To fulfil the functions, powers and duties assigned to Trey Legal by the legislation of the Russian Federation.
(B) To fulfil a contract to which you are a party, beneficiary or guarantor, as well as to conclude a contract on your initiative or a contract under which you will be a beneficiary or guarantor.
(C) To exercise the rights and legitimate interests of Trey Legal or third parties, including in cases provided for by the federal legislation of the Russian Federation.
(D) Other lawful grounds provided for by the legislation of the Russian Federation.
4. HOW DO WE PROCESS YOUR PERSONAL DATA?
We process your personal data both with the use of automation means and without the use of such means (mixed processing). When processing your personal data, we perform the following actions (operations) with personal data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, and destruction of personal data.
When collecting your personal data, we comply with the requirement to localize databases, i.e., to record, systematize, accumulate, store, update (update, change), and retrieve your personal data using databases located in Russia.
5. INFORMATION ABOUT YOU COLLECTED AUTOMATICALLY. USE OF COOKIES
In order to improve the Website and make it more user-friendly, Trey Legal may use special cookie technology. Trey Legal acknowledges that, to some extent, cookies may be considered as personal data, and their handling should be governed by the relevant legislation. In this section of the Policy, you can learn about what cookies are and how Trey Legal uses them.
What are cookies?
Cookies are small data files that the Website stores on your device and are used to record certain activities on the Website, by storing data that can be updated and retrieved. These files are stored on your device and contain data that does not harm your hardware. They are used to record your preferences, such as language selected and access details, and to personalise the Website. Cookies may also be used to store information about how you use the Website. For example, from which page or advertising «banner» you accessed the Website.
What types of cookies does Trey Legal use and for what purposes?
Analytical cookies: Trey Legal uses cookies to obtain information about your browser settings and to analyse your behaviour on the Website for the purposes of improving the Website’s performance.
In particular, Trey Legal uses the following tools, which involve the use of analytical cookies:
(A) Yandex.Metric, You can find more information about Yandex.Metric at: https://yandex.ru/support/metrika/
It’s possible that some cookies used on this website are not related to Trey Legal. This is because some pages contain elements obtained from third party pages. As these elements are obtained from other pages, Trey Legal cannot control the configuration of these cookies. If you wish to change your cookie configuration preferences, you should check with the websites of such third parties.
Your Ability to Manage Cookies
We will ask for your separate consent to process cookies. If you do not provide such consent, we will only process technical cookies necessary for the proper functioning of our Website.
You can also withdraw your consent to the processing of cookies and delete the cookies stored on your computer at any time by adjusting your browser settings. Below are links to further information on how to change the settings of various browsers:
(C) Chrome (RU): https://support.google.com/chrome/answer/95647?hl=ru
(D) Explorer (RU): https://support.microsoft.com/ru-ru/help/17442/windows-internet-explorer-delete-manage-cookies
(E) Firefox (RU): https://support.mozilla.org/ru/kb/vklyuchenie-i-otklyuchenie-kukov-ispolzuemyh-veb-s
(F) Safari (RU): https://support.apple.com/ru-ru/guide/safari/manage-cookies-and-website-data-sfri11471/mac.
If you want to have more control over cookie settings, you can install special programs or add-ons in your browser, known as anti-tracking tools, which allow you to choose which cookies you allow to be stored on your device.
6. HOW LONG WE PROCESS YOUR PERSONAL DATA
We process your personal data for no longer than is necessary to achieve the purposes of processing as outlined in the Policy.
Once the purposes of personal data processing have been achieved, Trey Legal will destroy the personal data (and ensure its destruction by third parties involved in the processing) within 30 days. We will also cease processing your personal data (and ensure its destruction by third parties involved in processing) if you withdraw your consent to data processing (in cases where consent is the only legal basis for processing your personal data).
Please note that in some cases, we may continue to process your data after you withdraw your consent if it is required to fulfil our obligations under applicable law or if the processing is necessary for the exercise of the rights and legitimate interests of Trey Legal and/or third parties.
If you wish to withdraw your consent to the processing of personal data, please notify us by emailing mail@trey.legal.
7. ARE THIRD PARTIES INVOLVED IN THE PROCESSING OF YOUR PERSONAL DATA?
Trey Legal does not sell or provide personal data to third parties outside the scope of this Policy without your express consent. Trey Legal may aggregate anonymized data with other information received from third parties and use it to enhance and personalize services, content, and advertising.
8. THIRD PARTY WEBSITES
The Website may include links to third-party websites, and third-party websites may also link to our Website.
Trey Legal is not responsible for the processing of your personal data on such third party websites or the policies and practices of their owners, administrators or others in relation to the processing of users’ personal data.
We therefore strongly recommend that you familiarise yourself with the terms of use and personal data privacy policy of each third party website you visit.
9. WHAT MEASURES DOES TREY LIGAL TAKE TO PROTECT YOUR PERSONAL DATA?
One of the key principles of Trey Legal’s processing of your personal data is ensuring its confidentiality and security. To achieve this, Trey Legal takes and will continue to take technical, legal, and organizational security measures in relation to your personal data, including but not limited to:
(A) Appointing a person responsible for organizing the processing of personal data, as well as a person responsible for ensuring the security of personal data in the information system.
(B) Establishing local regulatory acts concerning the processing of personal data.
(C) Assessing the potential harm that may be caused to Website users in the event of a breach of data protection laws in the Russian Federation, and aligning this potential harm with the measures taken to protect personal data.
(D) Providing training to employees directly involved in personal data processing, ensuring that they are familiar with the provisions of the laws of the Russian Federation on personal data and the local regulatory acts of Trey Legal on personal data processing, or providing relevant training to these employees.
(E) Ensuring uninterrupted power supply to devices used for accessing the information system.
(F) Providing unrestricted access to this Policy.
(G) Protecting the premises where the information system, containing your personal data, is processed, from unauthorized access, including by installing locks on the doors, implementing access control systems, and using video surveillance when permitted by law.
(H) Implementing appropriate mechanisms, such as usernames and secret passwords, to ensure that personal data is accessible only to authorized individuals who need such access to fulfil their duties.
(J) Checking and taking measures to ensure that every person authorized to access systems and/or folders where personal data is stored is aware of their duties and the processing procedures related to such data, as well as their responsibilities.
(K) Enforcing reporting and problem resolution procedures, along with measures taken to ensure the security level outlined in this Policy.
(L) Maintaining up-to-date incident logs that include the name of the responsible person(s), the time of the incident, any consequences, and actions taken in the event of a breach of personal data security.
(M) Informing Trey Legal employees involved in non-automated processing of personal data about the specifics and rules governing such processing.
(N) Storing tangible carriers of personal data in fireproof metal cabinets and safes in accordance with the requirements of the legislation of the Russian Federation.
(O) In cases of non-automated processing, ensuring that data processed for incompatible purposes are not recorded on a single tangible medium. Separate tangible media stored separately from each other are used for personal data processed for incompatible purposes.
(P) In cases of non-automated processing, separating personal data from other information by recording it on separate tangible media or in special sections or fields of forms and documents that may contain personal data.
Trey Legal will undertake other necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, transfer, dissemination, or other unlawful actions related to personal data, as provided for by the Federal Act of 27.07.2006 No. 152-FZ «About Personal Data», Resolution of the Government of 01.11.2012 No. 1119 «About Approval of Requirements for the Protection of Personal Data when Processing in Personal Information Systems».
10. YOUR RIGHTS IN RELATION TO THE PROCESSING OF PERSONAL DATA
You have the following rights in relation to the processing of personal data by Trey Legal:
(A) Withdraw consent to the processing of your personal data by Trey Legal.
(B) Request Trey Legal to clarify, delete or correct, block and destroy incomplete, incorrect, outdated, inaccurate, illegally obtained or personal data that are no longer necessary for Trey Legal.
(C) Access your personal data, including obtaining the following information from Trey Legal:
(i) Categories of personal data processed;
(ii) Purposes of personal data processing;
(iii) Details of individuals with access to personal data or who may be granted such access (excluding Trey Legal employees);
(iv) A list of your personal data being processed and the source from which it was obtained;
(v) The duration of personal data processing, including storage;
(vi) Other information as required by current Russian legislation.
(D) Require Trey Legal to notify all parties to whom incorrect or incomplete personal data have been previously disclosed of any corrections, deletions, or additions made.
(E) Exercise other rights in the field of personal data protection provided for by applicable Russian law.
To withdraw your consent to the processing of personal data, please send a request to: mail@trey.legal. Upon withdrawal of your consent, we will cease processing the data, destroy the personal data, and ensure that third parties involved in the processing also destroy it (unless further processing is required by applicable law or can be carried out on another legal basis).
11. CHANGE OF POLICY
Trey Legal reserves the right to change and update this Policy.
If we decide to change or update our Policy, we will publish those changes here to keep you informed of how we process your personal data.
If any changes to this Policy would require, according to applicable law, that we obtain your consent to further processing of data in accordance with the amended terms of the Policy, we will notify you and ask for your consent, providing you with an opportunity to opt out of accepting such changes and further processing of personal data.
12. WHOM CAN I CONTACT REGARDING THE PROCESSING OF PERSONAL DATA AND THE EXERCISE OF MY RIGHTS?
In order to exercise your rights and for any questions related to the processing of personal data, you can contact us:
(A) By email: mail@trey.legal; (and) or
(B) By post: Russian Federation, 117218, Moscow, Bolshaya Cheremushkinskaya Street, 34, office M316, Trey Legal LLC.
Please note that we do not consider anonymous inquiries. When we receive your inquiry, we may also ask you to confirm your identity (by providing your passport details) before sending you a reply.