Version No. 1 dated 24.10.2026. Effective date: 24.10.2026. Identifier: 2026-10-24-aml-1.
As a personal data subject, I freely, voluntarily and in my own interest give Individual Entrepreneur Andrei Viktorovich Svirin, INN 772872317733, OGRNIP 322774600176722 (the Controller), specific, purpose-defined, informed, conscious and unambiguous consent to the processing of my personal data on the terms below.
The Controller's correspondence address: P.O. Box 15, Moscow, 117647.
Email for personal data matters: zapros@aml-expert.ru.
The Controller's website: https://aml-expert.ru/ (the Website).
Abbreviations used in this document: INN — taxpayer identification number; OGRNIP — primary state registration number of an individual entrepreneur; OGRN — primary state registration number; LLC — limited liability company.
1. Processing purpose and legal basis
1.1. Consent is given to promote the Controller's services through direct email contact, create and administer an advertising subscription, implement message receipt settings, record consents and investigate technical failures or improper sending when registering a subscription.
1.2. Processing is based on clause 1 of part 1 of Article 6, Article 9 and part 1 of Article 15 of Federal Law No. 152-FZ of 27.07.2006, On Personal Data (the Personal Data Law).
1.3. Advertising may be sent where separate prior consent to receive it has been given under part 1 of Article 18 of Federal Law No. 38-FZ of 13.03.2006, On Advertising. This consent does not itself constitute consent to receive advertising.
2. Personal data categories
2.1. Consent covers the following personal data:
- a) email address;
- b) subscription identifier;
- c) information on consents expressed: choice result, dates and times of the relevant actions, document versions;
- d) subscription status and withdrawal information, including withdrawal date;
- e) technical server submission information: direct connection IP address, User-Agent, Accept-Language, approximate page completion time and time since the protective form token was issued.
2.2. Processing is limited to what is necessary for the purpose in clause 1.1.
2.3. This consent does not cover use of enquiry text, documents, photographs or other enquiry attachments, or information about the examination object, for advertising mailings or advertising profiling.
3. Data operations and processing methods
3.1. Within the stated purpose, the Controller may collect, record, systematise, accumulate, store, clarify (update, amend), retrieve, use, transfer (provide, grant access) to the persons in section 4 to the necessary extent, block, delete and destroy personal data.
3.2. Processing uses automated means, non-automated means or a combination of both.
3.3. Consent is expressed by independently selecting a separate subscription checkbox, not preselected and linked to the document, and submitting the form. The operational server checks the data and consents. The static preview prepares an email: it must be checked and sent independently, because preparing a draft does not transfer data to the Controller.
3.4. Advertising messages may be sent only with separately expressed prior consent to receive advertising. Entering an address in an enquiry form does not itself create an advertising subscription.
4. Persons involved in processing
4.1. Operational forms are processed by the website server. The Controller's email infrastructure is used to deliver notifications and store correspondence. In the static version, an email is prepared locally and sent through the visitor's chosen email application. Information is provided to technical contractors only to the extent necessary for the relevant task.
4.2. When sending an email independently, the visitor chooses the email application and sender's service. Server submission uses the Controller's email infrastructure. The message is processed to the extent necessary to consider the request, administer the subscription and honour withdrawal.
4.3. These persons receive only information necessary for the relevant technical task. Where personal data processing is entrusted to them, that instruction complies with part 3 of Article 6 of the Personal Data Law. Engaging third parties does not release the Controller from statutory duties to the data subject.
4.4. This consent does not authorise transfer of my address to third parties for their independent advertising of goods, work or services.
5. Consent duration and retention periods
5.1. On the operational website, a subscription is registered after verification of the separate form and two independent selections: advertising consent and consent to data processing for mailings. In the static version, the request is considered after the independently sent email is received. Preparing, copying or downloading a draft without sending it does not create a subscription.
5.2. Consent is valid for no more than three years from the date given, unless withdrawn earlier, the processing purpose is achieved or the relevant subscription is terminated. Data are processed no longer than required for the stated purpose. Extension requires new consent.
5.3. When the purpose is achieved, consent expires or the subscription ends, processing for advertising mailings stops. Where there is no independent lawful basis for further retention, the Controller ensures destruction in the manner and within the periods established by the Personal Data Law.
5.4. Minimum information needed to evidence consents, honour advertising withdrawal or protect rights and legitimate interests may be retained on an independent basis under clause 7 of part 1 of Article 6 of the Personal Data Law, subject to the data subject's rights and freedoms. Such information is limited to the address or other necessary subscription identifier, its status and consent and withdrawal records.
5.5. Information in clause 5.4 is retained only for as long as actually needed, but no more than three years from subscription termination. It may not be used to resume advertising messages. Its retention rests on an independent lawful basis and does not continue the validity of this consent.
5.6. Technical information in subclause e of clause 2.1 is retained for no more than 30 days from registration of the subscription or relevant withdrawal, then removed from the record during scheduled maintenance. It is not part of the minimum consent evidence retained for up to three years, is not used for behavioural analytics or profiling, and does not establish the sender's identity or the full duration of a website visit.
6. Consent withdrawal procedure
6.1. I may withdraw this consent at any time by sending notice to zapros@aml-expert.ru or to the Controller's correspondence address. To identify the subscription, it is recommended to specify the relevant email address.
6.2. Withdrawal can be requested by email or through the Unsubscribe page. On the operational website, after form processing, the server immediately marks the subscription inactive; advertising consents are not required for withdrawal. The static version prepares an email that must be sent independently. Withdrawal simultaneously withdraws advertising permission and this consent. Minimum withdrawal information is retained on an independent basis and is not used to continue advertising.
6.3. Upon receipt of the request, the Controller immediately stops processing personal data to promote services through direct contacts. The statutory period for destroying data does not permit continued advertising processing or advertising messages after receipt of the request.
6.4. If data retention is no longer needed for processing purposes and no independent lawful basis exists, the Controller ensures destruction within the statutory periods; part 5 of Article 21 of the Personal Data Law applies to withdrawal. Minimum information may be retained only subject to clauses 5.4 and 5.5.
6.5. Withdrawal does not affect the lawfulness of processing before it was received.
7. Voluntary nature and final provisions
7.1. Giving this consent is voluntary and is not a condition for considering an enquiry, receiving a response, entering into a contract or providing services. Refusal or withdrawal does not restrict use of the Website or submission of enquiries.
7.2. This consent is separate from consent to receive advertising, consent to process an enquiry and consent to optional analytics. It does not replace those consents or expand their scope.
7.3. Changes to this document do not alter the scope of consent previously given. If processing for other purposes or an expanded set of data is needed, new consent is obtained before that processing starts.
7.4. Procedures for exercising data subject rights and general protective measures are set out in the Personal Data Processing Policy: https://aml-expert.ru/legal/privacy-policy/.