Policy on the processing of
⚠️ Internal block: delete before publishing
This is a draft, not a policy in force. It follows the structure required by art. 18.1 of 152-FZ and the operator and processor details are filled in, but it cannot be published yet.
- The Russian location is a condition, not a fact. Section 10 states that the servers are in Russia. The provider also runs an Amsterdam site, and the studio already has a node there: bringing the site up on it would make section 10 false and breach art. 18(5) of 152-FZ.
- No notification has been filed with Roskomnadzor. Processing personal data requires notifying the supervisory authority; a policy does not replace it.
- The text has not been reviewed by a lawyer. It was not written by one. For a product sold to lawyers, a published policy with a defect costs more than in any other niche.
- HTTPS is not yet in place. Until a certificate exists, section 11 is not true.
0. Which version prevails
This English text is provided for information only. The policy is drawn up under the law of the Russian Federation, and the Russian version has legal force. Where the two differ, the Russian text applies. It is available at https://lawatech.pro/ru/privacy.
1. What this document is and what it covers
This Policy sets out how personal data of individuals who use the site lawatech.pro (the “Site”) is processed and protected. It is the publicly available document required by art. 18.1(2) of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
It covers data the Operator receives from visitors to the Site: through the pilot application form and through the contacts published on the Site.
It does not cover data that law firms using the Lawa.tech product process about their own clients inside the system. That is a different relationship, described in section 13.
2. The Operator and how to reach it
- Name
- Joint-stock company “ALLO, DIREKTOR” (AO “ALLO, DIREKTOR”)
- OGRN (state registration number)
- 1267700249695
- INN (taxpayer number)
- 7720969610
- Address
- 2-ya Entuziastov st. 5, block 40, unit 6/3, Perovo, Moscow 111024, Russian Federation
- Email for personal data enquiries
- hello@lawatech.pro
3. Definitions
“Personal data”, “processing”, “operator”, “data subject”, “blocking”, “destruction” and “cross-border transfer” carry the meanings given in art. 3 of 152-FZ.
User — an individual who has sent their data to the Operator through the Site.
4. What data is processed
The Operator processes only what the User provides about themselves, by filling in the application form or writing to the published contacts.
| Data | Required | Why |
|---|---|---|
| Name or form of address | yes | to address the User in correspondence |
| Firm or practice name | yes | to understand the context of the enquiry |
| Main practice area | yes | to select relevant materials |
| Number of open cases | optional | a preliminary sense of scale |
| Contact: email, Telegram handle or phone number | yes | to send a reply |
| Message text | optional | the substance of the enquiry |
The Operator does not request or process special categories of personal data (art. 10 of 152-FZ) or biometric personal data (art. 11). If a User volunteers such information in free text, it is deleted.
The Operator does not ask for information about the User’s own clients or anything covered by legal professional privilege. The free-text field is not intended for it.
Data processed automatically
The Site sets no cookies to identify the User, carries no web analytics and does no profiling. Data transmitted technically when the Site is requested (IP address, browser version, time of request) is processed to the extent ordinary for a web server — see section 9.
5. Purposes
- Reviewing the pilot application and replying to the User.
- Corresponding about the enquiry and arranging a meeting.
- Meeting obligations imposed on the Operator by Russian law.
Personal data is not used for advertising or newsletters. That would require separate consent.
The Operator makes no decisions producing legal effects for the User solely on the basis of automated processing.
6. Legal grounds
- Consent of the data subject — art. 6(1)(1) of 152-FZ, given by a separate action when the form is submitted. The box is not pre-ticked.
- Compliance with statutory obligations — art. 6(1)(2), for retaining documents and answering enquiries.
7. How, on what terms, and for how long
Processing is mixed — with and without automation — and covers collection, recording, organisation, storage, updating, use, transfer within the limits of section 9, blocking, deletion and destruction.
How an application reaches the Operator. As at this version, the form does not send data to the Operator’s server: the answers are composed into an email in the User’s own mail client, and the User sends it. If that changes, this section will be updated before such a transfer is switched on.
Retention. Data is kept until the purpose is met, and no longer than one year from the User’s last contact, unless a longer period is required by law. Once the purpose is met, or on withdrawal of consent, data is destroyed within thirty days.
8. Consent and its withdrawal
Consent is given freely, by the User’s own will and in their own interest, specifically, informedly and unambiguously — by a separate tick in the form. Without it the form does not submit.
Withdrawal. Consent can be withdrawn at any time by writing to hello@lawatech.pro. No particular form is required.
9. Third parties and cross-border transfer
The Operator does not sell personal data, does not pass it to advertising networks and does not disclose it to third parties, other than as set out below and as required by law.
Parties involved in processing
- OOO “TAIMVEB.KLAUD” (Timeweb Cloud), Russian Federation
- The only party the Operator involves in processing. It provides hosting for the Site and runs the Operator’s email: it processes the web-server data named in section 4 and stores correspondence. Both the Site and the mailbox sit on servers in the Russian Federation.
Resources the User’s browser contacts
Opening a page of the Site makes no request to any third-party service. Fonts, styles and scripts are served from the Site itself; no content delivery networks, advertising or analytics services are loaded.
Telegram buttons are ordinary links: the User follows them by their own action, and nothing is requested from that service beforehand.
10. Where the data is stored
Recording, organisation, accumulation, storage, updating and retrieval of personal data of citizens of the Russian Federation use databases located in the Russian Federation, as art. 18(5) of 152-FZ requires.
Hosting: infrastructure of OOO “TAIMVEB.KLAUD” (Timeweb Cloud) in Russian data centres — both the Site and the Operator’s mailbox. The same provider’s sites abroad are not used.
A note on section 7: while the form sends nothing to a server, the mailbox is the primary place where personal data from enquiries lives, so the localisation requirement applies to it first of all.
11. Safeguards
- access to enquiries limited to those who need it to reply;
- data travels between the User’s browser and the Site over a secure protocol;
- correspondence is kept in accounts protected by multi-factor authentication;
- data is destroyed once the purpose is met and on withdrawal of consent.
12. Rights of the data subject
- to obtain information about the processing of their data (art. 14(7) of 152-FZ);
- to require that data be updated, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose;
- to withdraw consent — see section 8;
- to complain about the Operator’s acts or omissions to the supervisory authority or in court.
13. Law firms’ client data — a different role
The Lawa.tech product is built for law firms and processes information about their clients. In that relationship the law firm is the operator, and Lawa.tech acts as a processor on its instructions (art. 6(3) of 152-FZ) under a written processing mandate.
14. Changes
The Operator may amend this Policy. The version in force is always published at https://lawatech.pro/en/privacy, with the Russian original at https://lawatech.pro/ru/privacy.