Version No. 1 dated 24.10.2026. Effective date: 24.10.2026. Identifier: 2026-10-24-aml-1.
1. Scope
1.1. These terms govern transfer of documents, photographs and other files (the Materials) to Individual Entrepreneur Andrei Viktorovich Svirin, INN 772872317733, OGRNIP 322774600176722 (the Controller), through the enquiry form at https://aml-expert.ru/ and in subsequent correspondence concerning that enquiry.
1.2. Correspondence address: P.O. Box 15, Moscow, 117647. Email for Materials and personal data matters: zapros@aml-expert.ru.
1.3. INN — taxpayer identification number; OGRNIP — primary state registration number of an individual entrepreneur.
2. Sender's confirmations
2.1. By transferring Materials, the sender confirms that they were obtained lawfully and that the sender has the necessary right or other lawful basis to transfer them to the Controller and allow the Controller to review them for consideration of the enquiry.
2.2. If acting for another person, the sender confirms the appropriate authority. If Materials contain other persons' personal data, legally protected information or intellectual property, the sender ensures an applicable basis for transfer and use within the enquiry. Consents and permissions required by law must be obtained before transfer.
2.3. At the Controller's reasoned request, the sender provides information and documents establishing authority and the legal basis for transfer. Before sending, the sender removes or conceals information unnecessary for considering the enquiry.
2.4. The sender is liable for breaching their duties and the accuracy of their representations within the limits established by Russian Federation law. These terms do not impose unconditional liability on the sender for all the Controller's actions or release the Controller from their own statutory duties and liability.
3. Permitted use of Materials
3.1. Within the sender's rights, transfer of Materials permits the Controller to receive, review, technically copy, store, analyse and use them only to the extent necessary to consider the enquiry, clarify circumstances, make a preliminary assessment and prepare a response. Personal data are processed only where there is an independent statutory basis.
3.2. Transfer of Materials does not assign exclusive rights or permit publication, independent advertising use, inclusion in public databases or transfer to analytics services. Disclosure to others is permitted only to the necessary extent on an applicable basis, including technical processors identified in the Policy or cases provided by law.
3.3. If a contract is concluded, use of Materials to provide the service is governed by that contract and applicable legal bases. The initial enquiry alone does not authorise use of any information for any examination.
3.4. The sender's confirmation does not constitute consent from every person mentioned in the Materials. The Controller independently verifies a sufficient processing basis. Where a lack of basis or excessive information is identified, use is restricted; unlawfully processed data are blocked and deleted within statutory periods.
4. Retention and deletion
4.1. Enquiry Materials where no contract is concluded, including email copies, are retained for no more than 90 calendar days from the last substantive message or telephone conversation. If interaction does not continue, the period starts on the enquiry date. After the purpose is achieved or the period expires, they are deleted unless there is an independent retention basis.
4.2. On the operational website, files are temporarily uploaded to the server handler for checking and creation of an email with attachments. Temporary copies are deleted after the sending attempt. No permanent public archive or file content log is created. Email copies are subject to clause 4.1. In the static preview, the browser reads files to prepare an .eml file without uploading them to the handler; the draft must be sent independently.
4.3. If a contract is concluded, necessary Materials and prepared documents are processed on the basis of the contract and law. Retention periods for mandatory accounting documents and information needed to protect rights are determined separately. Such a basis does not permit retention of excessive Materials.
4.4. The sender or data subject may contact the Controller about deletion of Materials. Requests are considered after checking authority and applicable retention grounds. Minimum acceptance records for these terms may be retained within the limits and on the bases specified in the Personal Data Processing Policy, without file contents or names.
5. Acceptance of the terms
5.1. When selecting files, the sender independently selects a separate checkbox, not preselected and beside a terms link, confirming lawful acquisition and the right to transfer the Materials. The operational handler checks the selection and version 2026-10-24-aml-1; minimum acceptance information is retained with the enquiry record for no more than 90 days from registration, without file contents or names. The static version includes the information in an email draft that must be sent independently to transfer it.
5.2. This selection confirms the Materials transfer terms and does not replace separate personal data processing consent. If no files are transferred, the Materials checkbox is not required.
6. Information on financial transactions and additional materials
The form transfers electronic documents and files relating to the task. Transfer of large document volumes or particularly sensitive information must be agreed separately. Do not send passwords, verification codes, online banking access, seed phrases or private keys.
For preliminary consideration, useful materials include the complete bank request or notification, statements, contracts and primary documents, information about activities and counterparties, a chronology of events and explanations previously submitted. The materials required depend on the task and are agreed before transfer.