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Privacy Policy

PRIVACY POLICY OF THE INTERNATIONAL GROUP OF COMPANIES “ROSKO – CONSULTING AND AUDIT” (“ROSKO”) REGARDING THE PROCESSING OF PERSONAL DATA, CONSENT TO THE PROCESSING OF PERSONAL DATA

CONSENT TO THE PROCESSING AND CROSS-BORDER TRANSFER OF PERSONAL DATA VIA THE “GOOGLE ANALYTICS” SOFTWARE IN THE INTERNATIONAL GROUP OF COMPANIES “ROSKO – CONSULTING AND AUDIT” (“ROSKO”)

An individual (hereinafter referred to as the Personal Data Subject), by filling out and submitting the "Submit Application" web form to the RosCo Group of Companies on the website https://rosco.com.ru/ (hereinafter referred to as the Website), specifically: "RosCo – Consulting Audit" (https://rosco.com.ru/), "Ask a Question" (https://rosco.com.ru/, https://rosco.com.ru/clients/), "Request a Call" (https://rosco.com.ru/), "Leave Your Feedback" (https://rosco.com.ru/recommendations/), acting freely, by their own will and in their own interest, and also confirming their legal capacity, gives their consent to the personal data operator for the processing and transfer of their personal data into systems based on the software tools "Yandex Metrica", "Google Analytics" (hereinafter referred to as the "Consent") under the following conditions:

1. The personal data operator (hereinafter – Operator) is the RosKo Group of Companies (INN: 5402192260, legal address: 127473, Moscow, 1st Volkonsky Lane, 13, bldg. 2, floor 2, office No. 12), which provides a wide range of services worldwide in the field of legal and tax consulting, audit, appraisal, and accounting services (hereinafter – “RosKo”), located at the domain name https://rosco.com.ru/.

2. This Consent is developed in accordance with and in execution of the requirements of the Federal Law of 27.07.2006 No. 152-FZ “On Personal Data” (hereinafter – the Personal Data Law) to ensure the protection of the rights and freedoms of a person and citizen when processing his/her personal data, including the protection of the rights to privacy, personal and family secrets.

3. The consent is given for the processing of personal data: surname, first name, as well as contact details: telephone, e-mail, website visitors’ “Cookies” files; data from metric systems (information about the operating system, browser, device location, device type, screen resolution, source of transition to the website, actions on the website, website visitor’s identifier in the metric system).

4. The consent is given for the cross-border transfer of the personal data of the data subject via the “Google Analytics” software, in accordance with Article 12 of the Federal Law of 27.07.2006 No. 152-FZ “On Personal Data”.

5. Personal data are processed by the Operator in order to provide and render legal and tax consulting, audit, appraisal, and accounting services to Data Subjects; to improve the quality of services provided; to communicate with Data Subjects for sending notifications, information and requests related to the Operator’s activities, including advertising content, as well as for processing inquiries, statements, applications and other messages from Data Subjects; to conduct statistical and other research based on anonymized personal data.

6. The processing of personal data is carried out using automation tools or without using such means, including collection, recording, systematization, accumulation, storage, updating (modification, change), extraction, use, blocking, deletion, destruction, and anonymization of personal data.

7. The consent comes into force at the moment the feedback form is sent and is valid until the purpose of processing specified in paragraph 4 of this Consent is achieved.

8. The consent may be revoked by sending a written application to the Operator (Russia, Moscow, 1st Volkonsky Lane, 13, bldg. 2, 2nd floor) or in the form of an electronic document signed in accordance with the federal law on electronic signature. At the same time, the Operator has the right to continue processing personal data without consent if there are grounds specified in paragraphs 2-11 of part 1 of article 6, part 2 of article 10, and part 2 of article 11 of the Federal Law No. 152-FZ “On Personal Data”.

PRIVACY POLICY OF THE INTERNATIONAL GROUP OF COMPANIES “ROSKO – CONSULTING AND AUDIT” (“ROSKO”) REGARDING THE PROCESSING OF PERSONAL DATA

1. GENERAL PROVISIONS

1.1. This Privacy Policy of Personal Data (hereinafter – the Privacy Policy) applies to all information that the RosKo Group of Companies, providing a wide range of services worldwide in the field of legal and tax consulting, audit, appraisal, and accounting services (hereinafter – “RosKo”), located at the domain name https://rosco.com.ru/, has developed in execution of paragraph 2, part 1, article 18.1 of the Federal Law of 27.07.2006 No. 152-FZ “On Personal Data” (hereinafter – the Personal Data Law) to ensure the protection of the rights and freedoms of a person and citizen when processing his/her personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. The Privacy Policy applies to all personal data processed by RosKo and extends to personal data processing relations that arose at RosKo both before and after the approval of this Privacy Policy.

1.3. The Website Administration does not verify the accuracy of personal data provided by the Website User.

1.4. In compliance with part 2, article 18.1 of the Personal Data Law, this Privacy Policy is published in free access in the information and telecommunication network Internet on the RosKo website: https://rosco.com.ru/.

2. DEFINITION OF TERMS

2.1. The following terms are used in this Privacy Policy:

2.1.1. “Website Administration (hereinafter – Website Administration)” – authorized employees managing the website, acting on behalf of “RosKo,” organizations that organize and/or carry out the processing of personal data, and also determine the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.1.2. “Personal data” – any information relating directly or indirectly to an identified or identifiable individual (data subject).

2.1.3. “Personal data operator” – a state body, municipal body, legal or natural person, independently or jointly with others organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.

2.1.4. “Personal data processing” – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, updating (modification, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.1.5. “Confidentiality of personal data” – a mandatory requirement for the personal data Operator or any other person who has access to personal data not to allow their dissemination without the consent of the data subject or the presence of another legal basis.

2.1.6. “User of the RosKo website (hereinafter – User)” – a person who has access to the RosKo Website via the Internet and uses the RosKo Website.

2.1.7. “IP address” – a unique network address of a node in a computer network built according to the IP protocol.

2.1.8. “Cookie files (Cookies)” – a text file with data written to the browser by the Operator’s website server visited by the User. Cookie files contain information that may be needed by the Operator’s website or another website to interact with the User and personalize his/her experience, identify the User’s internet browser, and are generally necessary for the uninterrupted and full functioning of the Operator’s website and its features.

2.1.9. “Cross-border transfer of personal data” – the transfer of personal data to the territory of a foreign state, to the authority of a foreign state, to a foreign individual or foreign legal entity.

3. PURPOSES OF COLLECTION AND PROCESSING OF USERS’ PERSONAL DATA

3.1. The website stores Users’ personal information in accordance with the internal regulations of specific services.

3.2. The confidentiality of the User’s personal information is maintained, except in cases where the User voluntarily provides information about himself/herself for general access to an unlimited number of people. When using certain services, the User agrees that a certain part of his/her personal information becomes public.

3.3. The personal data of the User may be used by the Website Administration of “RosKo” for the following purposes:

3.3.1. Identification of the User registered on the RosKo website when placing an order for the conclusion of a service contract with RosKo.

3.3.2. Providing the User with access to personalized resources of the RosKo Website.

3.3.3. Establishing feedback with the User, including sending notifications, requests related to the provision of services, processing requests and applications from the User.

3.3.4. Determining the User’s location to ensure security, prevent fraud.

3.3.5. Confirming the accuracy and completeness of personal data provided by the User.

3.3.6. Creating an account for the purchase of services, if the User has given consent to create an account.

3.3.7. Notifying the User of the Website about the provision of services.

3.3.8. Providing the User with effective customer and technical support in case of problems related to the use of the Website.

3.3.9. Providing the User, with his/her consent, with product updates, special offers, information about prices for RosKo’s services.

3.10. Carrying out advertising activities with the User’s consent.

4. SUBJECT OF THE PRIVACY POLICY

4.1. This Privacy Policy establishes the obligations of the RosKo Website Administration for non-disclosure and ensuring the regime for protecting the confidentiality of personal data that the User provides at the request of the Website Administration during registration on the Website or when placing an order for the provided service.

4.2. Personal data permitted for processing under this Privacy Policy is provided by the User by filling out the registration form on the RosKo Website in the relevant sections: “ORDER A SERVICE”; “REQUEST A CALL”; “FEEDBACK”; “CALL BACK”; “PAYMENT” and includes the following information:

  • User’s surname, first name, patronymic;
  • User’s contact phone number;
  • User’s e-mail address;
  • Cookie files.

4.3. The RosKo website protects Data that is automatically transmitted in the process of viewing advertising blocks and when visiting pages with a statistical system script installed:

  • IP address;
  • information about the browser (or another program that provides access to advertising);
  • access time;
  • the address of the page where the advertising block is located;
  • referrer (address of the previous page);
  • Cookie files.

4.3.1. The website collects statistics about the IP addresses of its visitors. This information is used to identify and resolve technical problems, to control the legality of financial payments.

5. CONDITIONS FOR PROCESSING USERS’ PERSONAL INFORMATION AND ITS TRANSFER TO THIRD PARTIES

5.1. The website stores Users’ personal information in accordance with the internal regulations of specific services.

5.2. The confidentiality of the User’s personal information is maintained, except in cases where the User voluntarily provides information about himself/herself for general access to an unlimited number of people. When using certain services, the User agrees that a certain part of his/her personal information becomes public.

5.3. The processing of the User’s personal data is carried out in accordance with the time limits set out in section 10 of this Policy, by any legal means, including in personal data information systems using automation tools or without using such tools, as well as using the “Yandex.Metrica” software.

5.4. The User agrees that the Website Administration has the right to transfer personal data to third parties solely for the purpose of fulfilling the User’s order, as well as in the following cases:

5.4.1. The User has given consent to such actions.

5.4.2. The transfer is necessary for the User to use a certain service or to fulfill a specific agreement or contract with the User.

5.4.3. The transfer is provided for by Russian or other applicable legislation within the procedure established by law.

5.5. In the event of loss or disclosure of personal data, the Website Administration informs the User about the loss or disclosure of personal data.

5.6. The Website Administration takes the necessary organizational and technical measures to protect the User’s personal information from unlawful or accidental access, destruction, modification, blocking, copying, dissemination, as well as from other unlawful actions of third parties.

5.7. The Website Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.

5.8. To recognize visitors’ preferences, as well as the most popular sections of the Operator’s website, the Operator’s website uses web analytics services (software tools) Yandex.Metrica (hereinafter – Yandex) and Google Analytics (hereinafter – Google). This allows the Operator to more purposefully organize the content of pages in accordance with the interests and requests of the User, improving the quality of the content provided. By agreeing to these terms of the personal data processing policy, the User agrees to the transfer of his/her personal data to third parties in Yandex, Google for the purpose of improving the quality of use of this website.

Yandex processes the received information to evaluate the User’s use of the website, to prepare reports for the Operator on the website’s activities, and to provide other services. Yandex processes information in accordance with the terms of use of the Yandex.Metrica service.

Google allows us to collect and analyze information on how Users interact with the Operator’s website. Cookies are also used when obtaining this information.

5.9. The Operator’s website uses online marketing services (Yandex.Metrica, Google), applying retargeting technologies. In this case, information about products and services of interest to the User is stored in cookies, which is subsequently used to inform the User in accordance with his/her interests.

Google cookies make ads more attractive for Users and more effective for advertisers (by ensuring ad relevance, improving reports, increasing campaign effectiveness, allowing to avoid repeated display of the same ads to the User, etc.).

6. OBLIGATIONS OF THE PARTIES

6.1. The User is obliged:

6.1.1. To provide information about personal data necessary to use the RosKo Website.

6.1.2. To update, supplement the provided information about personal data in case of changes to this information.

6.2. The Website Administration is obliged:

6.2.1. To use the received information solely for the purposes specified in this Privacy Policy.

6.2.2. To ensure that confidential information is kept secret, not to disclose it without the prior written permission of the User, as well as not to sell, exchange, publish, or disclose in any possible way the transferred personal data of the User, except as provided for in paragraphs 5.4

6.2.3. To take precautionary measures to protect the confidentiality of the User’s personal data according to the procedure generally used to protect such information in the existing business turnover.

6.2.4. To block personal data related to the relevant User from the moment of the User’s appeal or request, or of his/her legal representative or authorized body for the protection of the rights of personal data subjects for the period of verification, in case of detection of inaccurate personal data or unlawful actions.

7. LIABILITY OF THE PARTIES

7.1. The Website Administration, which has not fulfilled its obligations, shall be liable for losses incurred by the User due to the unlawful use of personal data, in accordance with the legislation of the Russian Federation.

7.2. In the event of loss or disclosure of Confidential Information, the Website Administration shall not be liable if this confidential information:

7.2.1. Became public before its loss or disclosure.

7.2.2. Was received from a third party before it was received by the Website Administration.

7.2.3. Was disclosed with the consent of the User.

8. DISPUTE RESOLUTION

8.1. Before applying to the court with a claim for disputes arising from the relationship between the User of the RosKo Website and the Website Administration, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute).

8.2. The recipient of the claim, within 30 (thirty) calendar days from the date of receipt of the claim, shall notify the claimant in writing about the results of consideration of the claim.

8.3. If no agreement is reached, the dispute will be submitted to the judicial authority in accordance with the current legislation of the Russian Federation.

8.4. This Privacy Policy and the relationship between the User and the Website Administration are governed by the current legislation of the Russian Federation.

9. ADDITIONAL CONDITIONS

9.1. The Website Administration has the right to make changes to this Privacy Policy without the User’s consent.

9.2. The new Privacy Policy comes into force from the moment it is posted on the RosKo Website, unless otherwise provided by the new edition of the Privacy Policy.

9.3. All suggestions or questions regarding this Privacy Policy should be reported by email to: info@rosco.com.ru.

9.4. The current Privacy Policy is posted on the page at: https://rosco.com.ru/privacy/.

9.5. This Privacy Policy is an integral part of the Website Use Agreement posted on the page at: https://rosco.com.ru/.

10. Composition and Categories of Processed Personal Data, Processing and Storage Periods

The processing of personal data is carried out by the Operator using automation tools, as well as without the use of such means (on paper).

The composition of the processed personal data, the periods of processing and storage

In accordance with the stated purposes of personal data processing, the Operator processes the following personal data within the designated periods:

Job candidates for the purpose of staff selection for open vacancies: full name, document data, phone number, e-mail address. Processing and storage period: processing until the decision on (non-)hiring for the vacancy, storage up to 3 years.

Clients (citizens of the Russian Federation) for the purpose of concluding and executing service contracts: full name, phone number, e-mail address. Processing and storage period: processing until the end of the contract (storage 5 years from the end of the contract).

Clients (citizens of the Russian Federation) for the purpose of providing additional services: full name, phone number, e-mail address. Processing and storage period: until the achievement of the purpose of processing personal data, or until the withdrawal of consent by the personal data subject.

Clients (citizens of the Russian Federation) for the purpose of fulfilling obligations under tax legislation, accounting legislation: full name, identity document number. Processing and storage period: processing until the end of the contract (storage 5 years from the end of the contract).

Clients (citizens of the Russian Federation) for the purpose of sending advertising and marketing mailings (news and special offers) by e-mail: full name, e-mail address. Processing and storage period: until the achievement of the purpose of processing personal data, or until the withdrawal of consent by the personal data subject.

Representatives of clients (minor citizens of the Russian Federation) for the purpose of sending advertising and marketing mailings (news and special offers) by e-mail: full name, e-mail address. Processing and storage period: until the achievement of the purpose of processing personal data, or until the withdrawal of consent by the personal data subject.

Clients (foreign citizens) for the purpose of fulfilling obligations under tax legislation, accounting legislation: full name, identity document number, phone number, e-mail address, migration registration document data, bank details. Processing and storage period: processing until the end of the contract (storage 5 years from the end of the contract).

Clients (foreign citizens) for the purpose of sending advertising and marketing mailings (news and special offers) by e-mail: full name, e-mail address. Processing and storage period: until the achievement of the purpose of processing personal data, or until the withdrawal of consent by the personal data subject.

Clients (foreign citizens) for the purpose of notifying the territorial body of the Federal Migration Service of the arrival of a foreign citizen at the place of stay: full name, identity document number, phone number, e-mail address, migration registration document data. Processing and storage period: processing until the end of the contract (storage 5 years from the end of the contract).

Clients (foreign citizens) for the purpose of renting ski equipment: full name, phone number, identity document data. Processing and storage period: until the end of the contract.

Clients (foreign citizens) for the purpose of improving the quality of service when automating the inventory rental process: full name, phone number. Processing and storage period: until the achievement of the purpose of processing personal data, or until the withdrawal of consent by the personal data subject.

Operator’s website visitors’ data for the purpose of collecting website visit statistics, analyzing and improving the operation of the website’s services: user session identifier, browser name and version, IP address, location, information collected through metric programs. Processing and storage period: until the end of the user session (for session cookies), until the expiration date (for persistent cookies, for which the maximum validity period is 1 year).

11. Cross-Border Transfer of Personal Data

11.1. Before starting activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

11.2. Before submitting the above notification, the Operator is obliged to obtain from the authorities of the foreign state, foreign individuals, foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.

11.3. The cross-border transfer is carried out via the “Google Analytics” software, which processes and transfers the personal data of the data subject outside the territory of the Russian Federation.

Updated “22” July 2025