Privacy policy

Personal data protection policy

1. General provisions

1.1. This Personal Data Processing Policy (the “Policy”) adopted by INFRALEX, registered at: 123112, Russia, Moscow, Presnenskaya naberezhnaya, 8, bldg. 1. Business quarter "Moscow City" Tower "City of Capitals" North block 5th floor, office 11 defines the main principles, objectives, procedure and conditions of processing personal data of Visitors to the website, as well as the measures to ensure that such personal data is secure and protected.
1.2. This Policy has been developed in compliance with the Russian Constitution and statutory and other regulations of the Russian Federation in the sphere of personal data and has been published for open access at INFRALEX website at:
1.3. The terms used in this Policy are interpreted as defined in Federal Law No. 152-FZ “On personal data” dated 27 July 2006.
1.4. INFRALEX guarantees that personal data it received shall be treated confidential having regard to the provisions of this Policy and undertakes to use such personal data only for the purposes set out in the Policy.

2. Definition and composition of personal data

2.1. The list of personal data to be safeguarded at INFRALEX shall be formed in accordance with Federal Law No. 152-FZ “On personal data” dated 27 July 2006.
2.2. INFRALEX shall process and safeguard personal data (including the surname, name, place of work, position, contact phone number, email, etc.) of the Visitors to INFRALEX Website at (the “Website”), as well as personal data coming to the INFRALEX corporate email ending with (the “Corporate Email”) of personal data subjects who expressed their Consent to the processing of their personal data (the “Consent”) by submitting the information through the forms they select (the “Forms”) on the Website or by sending an email. The moment at which the Consent is accepted will be the marking of the corresponding field of the Form and the pressing on the button of ‘Submit Form’ on any page of the Website, as well as the pressing on the button of ‘Submit email’ to the Corporate Email, with such email containing personal data of the subject.
2.3. When visiting the INFRALEX Website, reading texts and loading other information, certain data is automatically registered on a PC from which a Website Visitor browses INFRALEX Website.  When visitors browse its Website, INFRALEX gathers the following information:

3. Purposes of processing personal data

3.1. Personal data of Website Visitors will be processed for the following purposes:

4. Principles of and timeframes for processing personal data

4.1. INFRALEX processes personal data based on the following principles:

4.2. INFRALEX will process personal data if either of the conditions below is met:

5. Rights and obligations of a personal data subject

5.1. A personal data subject has the right:5.2. Website Visitors must submit only accurate data about themselves.
5.3. A Visitor grants his/her Consent to the processing of his/her personal data for the whole period necessary for INFRALEX to attain the goals of processing such personal data.
5.4. A Visitor may revoke his/her Consent to the processing of his/her personal data by sending an application in writing to INFRALEX postal address at: 123112, Russia, Moscow, Presnenskaya naberezhnaya, 8, bldg. 1. Business quarter "Moscow City" Tower "City of Capitals" North block 5th floor, office 11 or to its corporate email address (
5.5. Persons who have transferred the data to INFRALEX via the Website about another personal data subject without having the consent of the subject whose personal data has been transferred will be held liable under Russian legislation.

6. Rights and obligations of INFRALEX

6.1. INFRALEX never asks a Website Visitor about his/her race, national origins, political views, religious and philosophical convictions, health, and private life.
6.2. When processing personal data INFRALEX may do the following: gather, record, systematise, accumulate, store, update (renew or modify), retrieve, use, transfer (distribute, provide or access), depersonalise, block, delete or destroy the personal data of a Visitor.
6.3. If Visitors take part in the events INFRALEX holds, INFRALEX may disclose the corresponding personal data of the Visitor to persons who participate in holding the event.
6.4. INFRALEX may not transfer personal data to any third party, except for the following persons:6.5. INFRALEX may not disclose personal data of a Website Visitor for any commercial purposes without his/her consent. The processing of a Visitor’s personal data for the purposes of promoting goods, work and/or services on the market by directly contacting a potential consumer using means of communications is only allowed with the Visitor's prior consent.
6.6. INFRALEX undertakes to warn persons who have received a Visitor’s personal data that such data may be used only for the corresponding purposes and to require that such persons confirm their compliance with this rule.
6.7. Persons who received a Visitor’s personal data must keep such data secret (confidential).
6.8. INFRALEX will process personal data of Website Visitors and undertake measures to protect such personal data in accordance with the provisions of this Policy and other bylaws INFRALEX may issue.

7. Protection and security of personal data

7.1. INFRALEX applies the corresponding standards of technical and operational security to protect information submitted by Website Visitors from unauthorised access, disclosure, distortion, blocking or destruction.
7.2. The measures INFRALEX applies include the following:7.3. Access to personal data is granted only to INFRALEX authorised employees who have undertaken to  keep such information confidential.

8. Storage of personal data

8.1. Personal data of Website Visitors is stored during the period required for the purposes for which such data has been submitted, or for the period stipulated by legislation.
8.2. Once such purposes are attained or the period for processing personal data has expired, the personal data of Website Visitors will be destroyed.

9. Log data, cookies and web beacons

9.1. INFRALEX Website gathers standard information from the session log, including IP-address, type and language of the browser, as well as data on the time of the visit and addresses of websites from which a visitor came. To ensure effective management of the Website and assist with setting the user’s interface, INFRALEX may use cookies (small text files stored in the visitor’s browser) or web-beacons (electronic images), together with tracking pixels enabling the Website to calculate the number of visitors to a specific page, and  may ensure access to specific cookie-files.

The standard information gathered will be used solely for strategic purposes. INFRALEX does not use personal data for the purpose of the personal identification of any Visitors. If, however, registered Visitors are authorised on the Website, INFRALEX will be able to use such data together with the information obtained via data analysis tools and cookie files so that to analyse how visitors use the Website.

9.2. When using the Website, a Visitor grants his/her consent to INFRALEX uploading cookie files to the Visitor’s device in accordance with the conditions above.

9.3. A Visitor can manage cookie files by using the browser settings. If cookie files are deleted, all data regarding the Visitor’s preferences will be deleted, including his/her preference regarding a refusal to use cookie files. If cookie files are blocked, changes may be reflected on a user’s interface and some of the Website's features may become unavailable.

10. Final provisions

10.1. This Policy will be amended or added to if the corresponding changes or additions are made to current Russian legislation on personal data. The Policy may be amended at any moment at the discretion of INFRALEX. The current version of INFRALEX Policy is always available for review by public at large at its permanent address:
10.2. All relationships involving INFRALEX relating to processing and protection of personal data which are not expressly reflected in this Policy will be regulated in accordance with Russian legislation on personal data.
10.3. Compliance with this Policy will be monitored by the person in charge of processing of personal data at INFRALEX.
The date of the latest update of the Policy is 24 December 2019.