When interacting with LIMITED LIABILITY COMPANY STALIROV AND COMPANY, visiting website stalirov.lawyer, social networks, contacting via Communication Tools, you agree to the Privacy Policy and consent to personal data collection, processing, storage and transfer.
This Privacy Policy (the “Policy”) describes the rules and principles for collecting and processing Personal Data of Users, Customers, Consultants by LIMITED LIABILITY COMPANY STALIROV AND COMPANY (“Stalirov&Co”), code: 37-2069123, acts as a Processor and in cases described herein may act as Data controller. Stalirov&Co is registered at 100 Overlook Center, 2nd floor, Princeton, New Jersey, 08540, USA.
References to the words “we”, “our” or “us” or similar words in content shall mean LIMITED LIABILITY COMPANY STALIROV AND COMPANY (“Stalirov&Co”) and Stalirov&Co. Affiliates, depending on the Policy context.
References to the words “you” or “your” or similar words herein shall mean Stalirov&Co’s Users, Customers and Consultants.
We are committed to protecting the privacy and security of Personal Data you provide to us, and we will only collect, use and share data in the ways described in this Policy.
1. TERMS AND DEFINITIONS
We use and define some terms with a capital letter; their use in the text of the Policy shall mean that they have a special meaning, which is defined in the description of such a term. Section 1 of the Privacy Policy provides definitions for some of these terms.
1.1. Affiliate - any organization that directly or indirectly controls, is controlled by or is under common control with Stalirov&Co.
1.2. Questionnaire - a list of questions designed into a document or web form for collecting Users, Customers and Consultants’ personal data.
1.3. External Resources - Stalirov&Co’s pages on LinkedIn, Twitter, Facebook, Instagram, as well as on Clutch, Upwork, media platforms.
1.4. Personal Data - information that identifies you as a specific person or can be identified to interact with you.
1.5. User - an identifiable and non-identifiable natural person interacting with the Website or External Resources.
1.6. Customer - individuals and legal entities that receive Services from Stalirov&Co and provide access to Personal Data on the basis of an agreement.
1.7. Third Parties - individuals and legal entities providing or receiving services from Customers on the basis of an employment, partnership or service agreement.
1.8. Consultants - individuals and legal entities providing services to Stalirov&Co on the basis of an agreement.
1.9. Website - information pages on the Internet hosted by stalirov.lawyer domain name. The domain name is registered and owned by Stalirov&Co. Website content is protected by copyright, trademark law, intellectual property law, and unfair competition law.
1.10. Communication Tools - email, mobile communications, IP telephony, corporate and mobile instant messengers Telegram, WhatsApp, Slack, Google Meet, Zoom, Microsoft Teams conferencing tools.
1.11. Advertising and Analytics Services - Google ADS, Google Analytics, Facebook ADS, Facebook Analytics, LinkedIn and other internal and external software solutions in the Internet marketing field.
1.12. Services - activities in the field of research, development and analysis of legal solutions provided by Stalirov&Co and Consultants.
1.13. EDPB (European Data Protection Board) - European Data Protection Board.
1.14. CCPA (California Consumer Privacy Act) - a California State statute designed to enhance privacy and consumer protection rights for residents of California and the United States.
1.15. Cookies are small text files that store information about your previous activities on the Website.
1.16. GDPR - General Data Protection Regulation (“GDPR”), which has been applied to regulate personal data processing since 25 May 2018.
2. PERSONAL DATA COLLECTION METHODS
2.1. We collect Personal Data of Users, Customers, Consultants in the ways provided below:
2.1.1. When filling out forms on the Website.
2.1.2. When communicating by Communication Tools.
2.1.3. When interacting with External resources.
2.1.4. When filling out Questionnaires and providing access to data.
2.1.5. When filling in the details in the non-disclosure agreement and for legal services.
2.1.6. When using the Advertising and Analytics Services.
2.1.7. At the time of participation in offline and online events by scanning QR codes and online business cards.
2.1.8. In the process of collecting and processing data from public resources: forums, aggregators, classifiers, directories.
3. PERSONAL DATA WE COLLECT
3.1. Personal data collected voluntarily at Users’ initiative. Stalirov&Co collects Personal Data of Users, Customers, Consultants for contacting via Communication Tools and/or provision of Services, including:
3.1.1. name, surname, address,
3.1.2. phone number/email address;
3.1.3. nickname in the Telegram/Whatsapp messenger and/or nickname in the social network Facebook/LinkedIn;
3.1.4. passport data and identification of the tax number;
3.1.5. type of activity, professional experience and areas of activity;
3.1.6. education, skills and competencies, information about employment;
3.1.7. marital status and financial well-being;
3.1.8. health data;
3.1.9. tax history and information about the offense;
3.1.10. information about nationality, race, language and religion;
3.1.11. genetic and biometric data;
3.1.12. political and philosophical beliefs.
3.2. Personal data collected automatically. The user consents to the automatic collection of data from a computer or mobile device when interacting with the Website, for example: User-Agent, IP address, time zone, device and browser type data, URL address of the page from which you visited the Website site, and third-party web resources that you navigate to exit the Website.
3.3. Users’ non-identifying personal data. We may collect zip code, demographic and statistical information about Users for analytics and market research purposes. We convert Personal Data into non-identifying information in program code, which is not considered Personal Data under the GDPR because it does not reveal your identity.
3.4. Combination of Personal Data and Non-Identifying Information. When Personal Data and non-identifying information are combined; it may be converted into information that can identify you. For example, in cases where the User's name and available profile on social networks are known. We will treat the combined information as Personal Data subject to processing in accordance with this Policy.
3.5. Information obtained from External Web Resources and Public Sources. Stalirov&Co may supplement the Personal Data collected with records from External Web Resources and public sources, including social networks, freelance exchanges or databases. When we combine information we receive from third parties with information we collect from you. We will treat such information as Personal Data in accordance with this Policy.
4. PURPOSE OF COLLECTING AND PROCESSING PERSONAL DATA
4.1. We collect Personal Data of Users, Customers, Consultants in order to provide the Services, fulfill obligations, and comply with laws and government requirements. We collect Personal Data to investigate, resolve and prevent disagreements and disputes. Purposes of collecting, processing and transferring Users, Customers, Consultants’ Personal data:
4.1.1. To provide Services and fulfill obligations to the Customers. We collect and store Personal Data the Users provide when using the Website and External Resources for communication via the Communication Tools. We receive Personal Data when developing business and commercial relationships with Customers for project management and task performance.
4.1.2. To enter into contracts with Consultants. We may publish current vacancies for the recruitment of Consultants. We collect and store Consultants’ Personal Data when conducting interviews and reviewing CVs. We collect and process Communications Consultants’ Personal Data, forms on the Website, Questionnaires and additional information collection. To apply for a vacancy, Consultants must complete the Questionnaire, as well as pass an interview, which may be a video/audio call using the Communication Tools. By completing the Questionnaire, the Consultant provides us with Personal Data and agrees that such data will be processed by Stalirov&Co. The Questionnaire data will be available for processing only to Stalirov&Co. The questionnaire includes the collection of such data: name, age, contact information, location, portfolio of work, information about employers, recommendations from employers, participation in ratings and awards, professional achievements, diplomas and certificates of education, hourly rate, marital status and health status.
4.1.3. To measure interest, search channels and Users’ interaction with the Website. We analyze the Personal Data we collect through User interaction with the Website to determine and segment the target audience and Customer environment, improve the functionality and correct errors on the Website, develop and adapt commercial and information content, update offers, prices and Services.
4.1.4. To create advertisements. We collect and process Personal Data to send one-time advertising notices to Users and initiate communication in order to provide the Services. We collect and process analytical and statistical data about Users to create contextual, targeted, online media advertising.
4.1.5. To create a security system in Stalirov&Co. We process and verify the Users, Customers, and Consultants’ Personal Data to authenticate and verify the identity, the accuracy of the information provided and to protect the interests of Stalirov & Co from fraud, abuse and damage to business reputation.
4.1.6. To comply with laws and internal regulations governing the provision of the Services. We process the Users, Customers, and Consultants’ Personal Data for business administration, creation and maintenance of Customer accounts in CRM, project management and task completion. Compliance with internal instructions and policies, fulfilling legal obligations under contracts, ensuring legal rights and protecting interests.
5. PERSONAL DATA ACCESS
5.1. Personal Data Access. We are committed to protecting and maintaining the confidentiality of the provided Personal Data, and to this end, we have implemented appropriate policies and technical measures to protect data under our control from unauthorized access, misuse or disclosure, alteration, destruction and loss, in accordance with the GDPR.
5.2. When granting Personal Data access to us you consent to Personal Data processing, transfer and storage by Stalirov&Co, its affiliates and Consultants. We undertake to take all necessary measures to ensure that Personal Data is processed in compliance with security rules and in accordance with the Policy provisions.
5.3. Access conditions. To provide the Services, Stalirov&Co may provide User and Customer’s Personal Data access to Consultants. Consultants engaged by Stalirov&Co undertake, under the contract, to take precautionary measures, respect the integrity and confidentiality of Users and Customers data. Stalirov&Co has a unified control system for Personal Data processing in the CRM system with a classification of access levels.
6. PERSONAL DATA TRANSFER
6.1. Stalirov&Co is an international company registered in the United States. We process and store Personal Data in the European Union. If necessary, we may transfer Personal Data to legal and financial Advisors engaged by Stalirov&Co to provide the Services. Stalirov&Co consultants can access the Users and Customers’ Personal Data to the extent necessary to fulfill obligations under contracts and assigned tasks. Stalirov&Co or Consultants may transfer Personal Data to the Customer's corporate systems.
6.2. When we share Personal Data with Consultants, we will comply with the safeguards required by the GDPR and the Policy. When transferring data to Consultants, we are guided by GDPR regulatory mechanisms, as well as enter into a Data protection agreement (hereinafter “DPA”) and Standard contractual clauses for international transfers (hereinafter “SCC”) approved by the EDPB in the EU. Customers can request DPO and SCC access for audit and reconciliation.
6.3. Consultants may collect Personal Data and access the Users, Customers, and Communication Consultants’ confidential information, on the Website or in the CRM system databases. Stalirov&Co collects and transfers tracking activities on your device, including cookies and web beacons, to Consultants. Consultants may access and process Users and Customers’ sensitive information.
6.4. Consultants who may receive Personal Data:
6.4.1. Lawyers who are employees.
6.4.2. Contractors and partners in legal services.
6.4.3. Digital agencies and service IT companies.
6.4.4. Agencies and contractors for content marketing and media buying.
6.4.5. Government and/or law enforcement agencies based on a formal request and/or court decision.
6.4.6. Insurance, postal and courier companies.
6.4.7. Companies providing services in the field of financial consulting and accounting.
6.4.8. Banks and payment systems.
6.4.9. Audit companies.
6.4.10. Customer audits.
7. PERSONAL DATA STORAGE
7.1. Stalirov&Co implements measures for Personal Data storage in accordance with GDPR and CCPA. Based on the fact that no method of storing information on the Internet is completely secure, Stalirov&Co does not fully guarantee the security of any information you transfer to us.
7.2. We carry out measures to secure the storage of Personal Data in accordance with Article 32 GDPR, such as: ensuring confidentiality, integrity, anonymization and encryption, availability and stability of processing services, timely restoration of access to data and testing the effectiveness of protective measures.
7.3. Stalirov&Co retains Customers and Consultants’ Personal Data for the duration of contract or for as long as it is necessary to fulfill obligations and provide Services, resolve disputes, prevent misuse of data, or until the User requests to delete the same. Stalirov&Co may retain Personal Data for 3 years from the date of the last interaction with the Website, in accordance with the obligations stipulated by the laws of the United States and the European Union.
7.4. Personal Data we process and store remains the Users, Customers and Consultants’ property.
7.5. In the event of changes to the Personal Data necessary for the provision of Services, the Users and Customers shall notify us of such changes.
8. DATA STORAGE SECURITY AND DPO
8.1. To control the storage and security of Users, Customers and Consultants’ data, Stalirov&Co engages a Data Protection Officer (hereinafter referred to as “DPO”) who is responsible for compliance with the personal data protection act, in accordance with articles 37, 38, 39 GDPR.
8.2. Pursuant to GDPR, Stalirov&Co engages DPO to perform the following tasks:
8.2.1. informing Users, Customers and Consultants when collecting and processing data;
8.2.2. monitoring compliance with the norms and requirements of the regulations for the data collection and processing;
8.2.3. representation in supervising authorities for compliance with regulations;
8.2.4. consulting in any situation фищге data collection, transfer and security;
8.2.5. consideration of Users, Customers, Consultants’ appeals and complaints to protect the rights.
8.3. We develop measures to securely store the Personal Data collected on servers and hosting, as well as provide data encryption and anonymization. Access to the Website, CRM system is encrypted using standard Transport Layer Security (“TLS”) technology. We also use strict HTTPS transport security.
8.3.1. Access control and management system. When granting access to sensitive data, several levels of protection are used.
8.3.2. Data transfer control. Data flow over Stalirov&Co internal networks is protected.
8.3.3. Data entry control. Stalirov&Co checks the changes made to data or data deletion from processing systems.
8.3.4. Availability control. Personal data is protected against accidental destruction or loss.
8.3.5. Data integrity control. Stalirov&Co uses firewalls, anti-virus software and conducts external and internal penetration testing.
8.4. Stalirov&Co is not responsible for leakage, unauthorized collection and disclosure, resale and misuse of Users, Customers, Consultants’ Personal Data that occurred in the CRM system, hosting provider or in other services and systems used by Stalirov&Co.
9. USE OF COOKIES. CONSENT TO USE
9.1. Stalirov&Co uses Cookies to improve and simplify the Users' experience with the Website. Cookies are necessary to save the settings you have chosen on the Website and to remember your preferences. We use cookies in accordance with the requirements of the GDPR and in accordance with the guidelines and rules provided by the EDPB. When using cookies, we rely on the legal grounds provided in the article 6 GDPR:
9.1.1. User’s consent;
9.1.2. Stalirov&Co’s legitimate interests
9.2. We inform the User, before placing Cookies on your device, by means of a pop-up message on the main page, when the User first visits the Website. By continuing to use the Stalirov&Co Website, you agree to the use of cookies.
9.3. For the Website operation, we use primary and secondary cookies. Primary cookies do not require your consent to use thereof, as they are necessary to ensure the Website operation; secondary cookies are collected and used if the User consents to this.
9.4. If you do not want to give consent or wish to withdraw your consent to the use of cookies, you need to block, delete or disable cookies. Disabling, deleting or blocking files affects the Website functionality, and you may be restricted from using certain features of the Website.
9.5. To disable, delete or block cookies, you need to change the cookie settings on your browser, such settings are usually located in the “Options” or “Settings” menu of your Internet browser, follow the instructions given in the following links:
9.5.1. Google Chrome;
9.5.2. Safari;
9.5.3. Mozilla Firefox;
9.5.4. Opera;
9.5.5. Microsoft.
10. COOKIE TYPES, PURPOSE AND RETENTION PERIOD
10.1. First-party: Cookie and other tracking technologies are necessary to use the Website and comply with applicable data protection laws. Stalirov&Co uses Cookies to provide the Services, identify Users, determine the service you connect to, check the functionality of the Website on your device, for example: whether the User's browser supports Cookies, whether the User has accepted consent to the use of Cookies or not.
10.1.1. Permanent: remain on the User's device for the period of time specified in the cookie, and are activated each time the User visits the Website that created that particular cookie.
10.1.2. Third-party Cookies are cookies that are set by a domain other than the one the Website User is visiting. If a User visits a Website and another domain sets a cookie through that Website, this will be a third party cookie.
10.1.3. Session: allow Website operators to link User actions during a browser session, with the browser session starting when the User opens the browser window and ending when the user closes the browser window. Session cookies are created temporarily, as soon as you close your browser, all session cookies will be deleted.
10.2. Additional:
10.2.1. Analytical: help us to understand how Users interact with the Website, such as which pages are visited, page loading rate. These cookies collect information anonymously to avoid identifying you and are only used to help us improve the Website, understand what interests you most about the Website.
10.2.2. Marketing: Used to display relevant ads. With their help, we enable Users to share our content on social networks such as Facebook and Instagram. In order to provide this service, we link to a third party Website called ShareThis.
10.2.3. Functional: Allow remembering Users preferences and choices they make on the Website and also provide you with enhanced functionality and personalization of the Website, including comments, widgets and online chat. These files may be installed by third party providers whose services we may add to pages of the Company's Website.
11. USER’S RIGHTS
11.1. Access right. The Privacy Policy lists the Users, Customers and Consultants’ Personal Data that Stalirov&Co collects and processes. The User, Customer and Consultant may obtain confirmation of Personal Data use and processing, as well as contact DPO in order to request access to the Personal Data we hold, in accordance with article 15 GDPR
11.2. Right to rectification. If the Personal Data Stalirov&Co retains and processes is inaccurate or incomplete, the User, the Customer and the Consultant have the right to update, correct, supplement their Personal Data, provided that they do it personally, and the identity as the subject of this data can be confirmed. The User may also contact DPO to access their Personal Data in order to update, correct and/or change it, in accordance with article 16 GDPR. We will inform you of the action taken within 30 business days of such a request. If you require Stalirov&Co to correct Personal Data already shared with Consultants and Advertising and Analytics Services, we will notify them of correction where such notice is possible.
11.3. Right to export. The User, Customer and Consultant may request the Personal Data transfer to third parties, in accordance with article 20 GDPR. You have the right to receive Personal Data in a structured, commonly used and machine-readable format and use it elsewhere or ask us to transfer it to a third party of your choice, provided you do so in person, and that your identity as the data subject can be verified. The export of personal information that we have already shared with Consultants and the Advertising and Analytics Services is carried out by these parties through your separate request.
11.4. Right to erasure. The User has the right to delete Personal Data in accordance with article 17 GDPR. Personal data, in this case, will be permanently deleted. In the event of a request for deletion, Stalirov&Co will inform you of measures taken and within 30 working days from the date of such request. If a User or Customer requests deletion of Personal Data that we have already shared with Consultants and the Advertising and Analytics Services, we will notify them of the deletion where such notice is available.
11.5. Right to restriction of processing. You can ask us to stop or suspend processing of Personal Data. In the event of a request to restrict processing, we will inform Users and Customers of measures taken within 30 business days of such a request. If you request to restrict the Personal Data processing after Stalirov&Co has shared it with third parties, we will notify them of such restriction where possible.
11.6. Right to object. The User, the Customer and the Consultant have the right at any time to object to the Personal Data processing in accordance with article 21 GDPR.
11.7. Right to withdraw consent to data processing. The User has the right at any time to withdraw its consent to the Personal Data processing, which was provided by Stalirov&Co. We rely on your consent as a legal basis for processing data; in the event that the User withdraws consent to processing, some functions of our Website may not be available.
11.8. The right not to be subject to automated decision-making in individual cases, including profiling. The User has the right not to be subject to a decision that is based solely on automated processing, including profiling, which gives rise to its legal consequences, according to article 22 GDPR.
11.9. Right to lodge a complaint with a supervisory authority. If you have any doubts about any aspect of Stalirov&Co's privacy policy, including how your personal data is processed, you can report it to the appropriate supervisory authority or contact Stalirov&Co DPO.
11.10. Stalirov&Co may deny Users, Customers and Consultants the right to access, correct, transfer, delete, object if Stalirov&Co acts as a Personal Data processor and is limited in authority by the data controller. In case of denial of right to access, correct, transfer, forget, object with regards to Personal Data, we shall inform you of the reasons within 30 (thirty) working days of such a denial.
11.11. Where User, Customer and Consultant’s identity is not verified or cannot be verified, we may request additional information or refuse to provide the opportunity to change/delete/transfer/export/withdraw/object to your Personal Data.
11.12. Stalirov&Co will use commercially reasonable efforts to comply with User requests for deletion, however, certain information will be retained on the Website. In addition, the rights described above may be limited, for example, if fulfilling your request would disclose another person's Personal Data, or if you ask us to delete information that we are required by law to keep, or if we have a legitimate interest in keeping, e.g. to prevent fraud.
11.13. Personal Data may be archived and information you update or delete may be retained for our administrative purposes to the extent permitted by law. We will not remove information that you have posted publicly using or in the Software. Stalirov&Co cannot delete all copies of information that was previously shared with others.
12. SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
12.1. This Supplemental California Privacy Notice applies only to California residents. This applies to the Personal Data we collect on the Website or through the Advertising, Analytics Services, and Communications.
12.2. The CCPA requires us to disclose information about the Personal Data categories we collect about consumers in California, the categories of sources from which the information was collected, the business or commercial purposes for which the information was collected, and the categories of parties with whom we share California residents’ Personal Data.
13. LINKS TO OTHER SITES
13.1. The Website may contain links to External Resources, including those integrated via API. If you follow a link to External Resources, you will be redirected to a website that may collect and process Personal Data.
13.2. The fact that Stalirov&Co refers to External Resources does not constitute an acknowledgment of our association with it, nor is it an acknowledgment that their privacy and/or information security policies comply with our Policy.
13.3. We do not control the External Resources that may be placed on the Website. External resources may place their own cookies or other files on your device, collect data, or solicit personal information from you. We recommend that you read the privacy policy of the External Resources that you visit by clicking on the links provided on the Stalirov&Co Website.
13.4. Spam Protection Policy. All commercial emails are sent to Stalirov&Co in full compliance with the US CAN-SPAM Act of 2003. We have developed internet marketing tools and methods to include a “permission-based” policy that prohibits the use of Users' emails for sending bulk mails.
13.5. If you believe that Stalirov&Co has sent you an unsolicited email, please let us know about your situation via our “Contact Us” web page. Your application will be reviewed within 15 working days.
14. MODIFICATIONS TO THIS POLICY
14.1. We have the right to change, update and supplement the Policy from time to time to ensure the Personal Data integrity, to notify of changes in the Personal Data use and to comply with GDPR/CCPA.
14.2. In case of material changes that relate to Personal Data, we notify Users, Customers and Consultants of such changes by posting news on the Website and/or using an e-mail newsletter. We recommend you review the Policy periodically to be informed about how we use your Personal Data.
14.3. In the event that you unsubscribe from emails in which we announce changes to legal documentation, Users, Customers and Consultants remain responsible for reviewing the same.
14.4. After making changes to the Policy, we have the right to request the Users, Customers and Consultants for repeated acceptance of the updated Policy. Changes to the current Policy will become effective 30 days after publication of the Policy amended new version.
14.5. Our electronic or otherwise retained copies of the Policy shall be deemed to be the original, complete, valid and enforceable version of this Policy in effect at the time of your interaction with the Website.
15.6. By continuing to interact with the Website, you confirm your acceptance of changes made to the Stalirov&Co’s Policy.
15. DISCLAIMER
15.1. Website content is compiled and updated by Stalirov&Co and the Consultants. Any liability for damages arising directly or indirectly from the use of the Website shall be excluded to the extent permitted by US and EU law.
15.2. Stalirov&Co shall not be responsible for the violation of your rights or third-party rights, if such a violation occurred as a result of sending any information through the communication forms or contacting via e-mail or via the Communication Tools. This limitation of liability does not apply to life- and/or health threatening situations resulting from willful or negligent violations on Stalirov&Co’s part.
16. CASES AND GUIDELINES
16.1. Stalirov&Co collects the Customers and Consultants’ Personal Data in order to publish cases, guidelines and information about team specialists. Customers and Consultants’ Personal Data may be available for public viewing on the Website, in “Cases”, “Reviews” and “About Us” sections.
16.2. We collect feedback and recommendations about Services from Users and Customers on the Website for Stalirov&Co. advertising and marketing promotion. Such information is used to respond to your requests, improve the quality of Stalirov&Co Services, develop new products, and attract new Customers.
16.3. If you would like to update or delete your case and/or guideline, contact us at: info@stalirov.lawyer.
17. FEEDBACK
17.1. If you have any questions regarding your data collection and processing by Stalirov&Co, contact Stalirov&Co DPO at the email address: dpo@stalirov.lawyer.
17.2. You also have the right to receive further information about your rights with regard to your Personal Data by sending an email to: info@stalirov.lawyer.
17.3. If you have an unresolved privacy or data usage issue that we have not satisfied, any questions or complaints regarding the Website or this Policy, contact us by sending an email to: info@stalirov.lawyer.
17.4. Stalirov&Co allows Users to opt out of receiving further e-mail messages about offers. Instructions on how to unsubscribe and remove your email address from the mailing list are included at the end of each email.
LLC Stalirov&Co
Address: 100 Overlook Center, 2nd floor, Princeton, New Jersey, 08540, USA
Code: 37-2069123
E-mail: info@stalirov.lawyer
CEO: Valeriy Stalirov