Website in Russia: Legal Requirements and Compliance

 

January 7, 2022

Anna Ivanova, Attorney at BRACE Law Firm ©

 

Currently, business development is virtually inconceivable without information technology. Most organizations, as well as individuals (individual entrepreneurs or the self-employed), disseminate information about themselves via the Internet. At the same time, current legislation establishes certain requirements for the content of websites, with liability provided for violations. Below, we consider the main requirements for websites.

Requirements for Advertising on Websites

According to Articles 2 and 3 of Federal Law No. 38-FZ dated March 13, 2006, On Advertising (the "Law on Advertising"), advertising is information distributed by any means, in any form, and using any media, addressed to an indefinite circle of persons and aimed at attracting attention to the object of advertising, forming or maintaining interest in it, and promoting it on the market. The requirements of this Law apply to advertising regardless of the place of its production, provided the advertising is distributed within the territory of Russia.

Furthermore, according to Article 2 of the Federal Law On Information, Information Technologies, and Information Protection, information is "information (messages, data) regardless of the form of its representation".

Thus, the main criteria for classifying information as advertising include:

• addressing an indefinite circle of persons;
• aiming to attract attention to the object of advertising.

According to FAS Russia, if information meets the criteria of advertising and, while having a certain target audience (for example, company clients, TV channel viewers, passers-by in a specific area), forms interest among an indefinite circle of persons and thus goes beyond its target audience, such information constitutes advertising.

As FAS Russia notes, "information about manufactured or sold goods (services provided) placed on the website of the manufacturer or seller of these goods (the person providing these services) is not advertising, provided that the specified information is intended to inform website visitors about the range of goods (services), rules of use, as well as directly about the seller, manufacturer of the goods, or the person providing the services, etc.; consequently, the provisions of the Law on Advertising do not apply to such information".

Additionally, announcements by individuals related to the sale of property or personal belongings are not advertising, as they do not pursue advertising goals.

According to FAS Russia specialists, information placed in reference and catalog publications containing an identical set of data about organizations and grouped by specific headings is of a reference and informational nature. This is because it aims to notify consumers about the existence of a particular economic entity and designate its type of activity. When placing brief, informational data in reference publications, advertising goals such as forming and maintaining interest in a specific legal entity and its product are not achieved. This is because such information, placed among similar, homogeneous data of many legal entities, does not allow for the highlighting of any one person or product to form interest in them. In this regard, FAS Russia does not recognize announcements by individuals placed on certain sites (for example, on the Avito website) as advertising.

General requirements for advertising are established in Article 5 of the Law on Advertising. This legal norm requires that advertising be fair and true.

Advertising is recognized as unfair if it:

1. Contains incorrect comparisons of the advertised product with products in circulation that are manufactured by other manufacturers or sold by other sellers. The Supreme Arbitration Court of the Russian Federation clarified that when analyzing information contained in advertising, one must keep in mind that the advertiser is liable for the accuracy of not only the information related to its own activities (product) being the object of advertising, but also information related to the activities (product) of its competitors, which is not the object of advertising. When comparing its own goods with competitors' goods in advertising, comparisons based on incomparable criteria or incomplete comparisons of goods are not allowed, as this distorts the perception of the advertised product and does not allow for an objective assessment of its properties. Therefore, advertising may be recognized as untrue even in cases where information that does not correspond to factual circumstances concerns the activities (product) of competitors.

In particular, the Directorate of FAS for the Republic of Tatarstan established the fact of distributing advertising for clothing on an official website with the text: "District... Improve with us... The best clothing in Kazan...". Such advertising was recognized as unfair because, in the opinion of the control authority: "The use of comparative characteristics of an advertising object with other goods in advertising, for example, by using the words 'best', 'first', 'number one', must be performed with an indication of the specific criterion by which the comparison is made and which has objective confirmation".

2. Defames the honor, dignity, or business reputation of a person, including a competitor. FAS Russia established a violation of advertising legislation based on citizen complaints. As established by the control authority, citizens were outraged by information contained in an advertisement for "Durex" condoms. They indicated that it insults and humbles their dignity as citizens of the Russian Federation, since the advertisement implies that Russia lacks a medical service system and health lifestyle propaganda, and that Russians treat their health and the health of others irresponsibly, and that the health organization system in Russia is low.
3. Represents advertising of a product whose advertising is prohibited by this method, at this time, or in this place, if it is carried out under the guise of advertising another product whose trademark or service mark is identical or confusingly similar to the trademark or service mark of the product for which relevant requirements and restrictions are established, or under the guise of advertising the manufacturer or seller of such a product.

For example, according to sub-clause "b" of Clause 1 of Part 2.2 of Article 27 of the Law on Advertising, the placement and distribution of advertising for risk-based games and betting carried out by gambling organizers in betting shops, and (or) means of individualization of gambling organizers in betting shops, are allowed: in public information and telecommunications networks: on websites registered as online media specializing in materials and messages of a physical culture and sports nature; on the official websites of all-Russian sports federations or professional sports leagues; on websites whose owner is the founder of a sports-oriented TV channel that is not a channel accessed exclusively on a paid basis and (or) using decoding technical devices. The control authority identified a violation on a website because the site was not registered as a publication specializing in physical culture and sports materials; was not an official website of sports federations or leagues; and the owner was not the founder of a sports TV channel as defined. Consequently, it was established that advertising for the "Leon" betting site distributed on the website contradicts the requirements of the Law on Advertising.

4. Constitutes an act of unfair competition in accordance with antimonopoly legislation. According to Article 14.3 of Federal Law No. 135-FZ dated July 26, 2006, On Protection of Competition, an act of unfair competition includes comparison with another competing economic entity and (or) its product by using words such as "best", "first", "number one", "most", "only", or other words or designations that create an impression of superiority of the product and (or) economic entity without indicating specific characteristics or comparison parameters that have objective confirmation, or if statements containing such words are false, inaccurate, or distorted. For example, the control authority established that based on the analysis of advertising text for the "Claude Monet" family cafe ("we have the most delicious and healthy children's menu at Moskovskaya 58") placed on the Internet, the comparison is made with similar services provided by other participants in the product market. As noted in the decision: "in this case, there are no parameters by which the accuracy of the specified comparison could be objectively verified, namely, determining based on what criterion the Claude Monet family cafe has the most delicious and healthy children's menu".

The Law on Advertising also establishes a fairly broad list of signs of untrue advertising. Advertising is recognized as untrue if it contains information that does not correspond to reality regarding: advantages of the advertised product; any characteristics of the product; the range and configuration of goods, their cost, delivery terms, exchange, warranty, exclusive rights to the product, results of research and testing; the manufacturer or seller of the advertised product, etc. For example, the Omsk Directorate of FAS Russia received materials from the prosecutor's office of the Central Administrative District of Omsk regarding the distribution of untrue advertising on a website. Specifically, in advertisements No. 10590992 and No. 10258739, one-room apartments in building No. 5 on 36-ya Severnaya St. in Omsk were offered for sale. However, at the time the advertising was recorded, the objects were unfinished construction projects, and the premises within them did not have "residential" status. Meanwhile, in advertisement No. 10258739, the "Building Characteristics" section indicated "Year of construction 2016", and in advertisement No. 10590992 — "Year of construction 2017".

Another important requirement of the Law on Advertising is that website advertising must not encourage the commission of illegal acts or call for violence and cruelty. For example, the control authority recognized advertising for electricity meters as encouraging illegal acts (distortion of actual consumption readings). It was established that the advertising messages suggested purchasing a meter that can be controlled to save consumer costs on consumed electricity ("Save wisely", "Pays for itself in a month", "Up to 75% energy savings"), which means making corrections to the readings. Meanwhile, the task of the meter is to display data on the quantitative value of energy resources actually produced, transferred, or consumed. Meters do not imply the possibility of savings and must not be subject to interference or reading adjustments.

Thus, advertising legislation establishes important requirements for advertising materials, which must be strictly observed when advertising on official websites. It is important to note that open access to advertising information on a website increases the risks of identifying possible violations, which requires a conscious approach to forming website content.

Another important point is the subsequent advertising of goods/works/services in email newsletters and (or) SMS messages if the email address or phone number data was obtained during the collection of information about website users. According to Part 1 of Article 18 of the Law on Advertising, the distribution of advertising over telecommunications networks, including through the use of telephone, facsimile, and mobile radiotelephone communications, is permitted only with the prior consent of the subscriber or addressee to receive advertising. For example, FAS Russia notes in one case that information sent in SMS messages containing data about the services of OJSC "Sberbank" was of a generalized nature. Such data is not personalized, despite mentioning the subscriber's first name and patronymic, and is of interest to an indefinite circle of persons and constitutes advertising. At the same time, advertising is recognized as distributed without the prior consent of the subscriber or addressee unless the advertiser proves that such consent was obtained. An advertiser must immediately stop distributing advertising to a person who has made such a request.

In view of the above, when performing mailings based on user information obtained through the website, it is necessary to obtain the website user's consent for these mailings. Furthermore, this issue is directly related to the processing of personal data of website users, which will be considered in more detail below.

Personal Data Protection on Websites

Personal data means any information relating to a directly or indirectly identified or identifiable individual (the "Subject of Personal Data") to whom the information is provided (Article 3 of Federal Law No. 152-FZ dated July 27, 2006, On Personal Data). However, the specified regulatory act does not contain a precise list of personal data. Nevertheless, in practice, any information that can identify website users in any way may be classified as personal data. A person collecting and processing personal data effectively acquires the status of a personal data operator, since by law, personal data processing means any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data. Any processing of personal data is carried out with the consent of the subject of personal data. Effectively, a website owner, upon receiving personal data from any user (surname, first name, patronymic, phone number, email address, passport data, etc.), acts as a personal data operator.

We remind you that processing personal data without the consent of the subject of personal data entails administrative liability in the form of a fine: from 3,000 to 5,000 rubles for citizens; from 10,000 to 20,000 rubles for officials; and from 15,000 to 70,000 rubles for legal entities (Article 13.11 of the CAO RF). It is also possible for a subject of personal data to file a lawsuit requesting the termination of personal data processing and payment of compensation for moral harm. Although current law enforcement practice in lawsuits by subjects of personal data emphasizes the need to prove that the personal data operator violated the rules of personal data processing (which may be difficult if consent for processing was obtained), measures must be taken to minimize such risks. Recommended measures include publishing a personal data processing policy (procedure) on the official website, which will provide for the procedure for withdrawing consent to process personal data. It is also necessary to ensure that before personal data is sent by the subject of personal data, automatic confirmation of consent to its processing is provided, with access to review the personal data processing policy.

In addition to the specified policy, it is necessary to comply with requirements for obtaining consent to process cookies, IP addresses, and other digital information collected by websites that can identify website users. We remind you that cookies are small text documents that a web server (website) saves on the user's computer via a browser. Such data collection is generally performed to optimize the website. However, the unscrupulous use of such data can lead to the direction of intrusive advertising to the user, as well as the leakage of other personal data. In the practice of Russian websites, cookie collection rules are included in the personal data processing procedure section. Such actions are not prohibited. Initially, the issue of the need to obtain consent for the use of cookies arose from the General Data Protection Regulation (GDPR) of the European Union. According to Article 7 of the specified document: "Where processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to processing of his or her personal data". Notably, this document effectively extends its effect not only to EU websites but also to websites of other countries visited by users located in the EU. Thus, no website owner is immune from the requirements of this regulation applying to a Russian website.

According to Clause 1 of Article 53 of Federal Law No. 126-FZ dated July 07, 2003, On Communications, information about subscribers includes: the F.I.O. or pseudonym of an individual subscriber; the name (corporate name) of a legal entity subscriber; the F.I.O. of the head of the organization and its employees; the subscriber's address or the address of user equipment installation; and other data allowing for the identification of the subscriber or their equipment. Providing information about individual subscribers to third parties can only be performed with their consent, except for cases provided for by legislation.

In this connection, it is necessary to place on the website rules for collecting cookies, IP addresses, and other digital identifiers of website users (including the possibility of establishing such a procedure within the personal data processing policy), as well as obtaining separate consent from the website user for the website owner to use cookies, IP addresses, etc. For example, in Clause 14 of the Policy for the Protection of Personal Data of Individual Clients of FSUE Russian Post and subsidiaries of FSUE Russian Post registered in the European Union, in addition to the conditions for providing consent to process cookies, it is reported that failure to provide such consent may result in restrictions on the use of certain website options.

It is important to note that Russian legislation is currently taking steps aimed at organizing relations related to personal data processing. For example, within the framework of the "Digital Home" federal project, Roskomnadzor developed the Code of Ethical Activity (Work) on the Internet, aimed at increasing the attention of citizens, government bodies, society, and the business community to the need to build a safe information space on the Internet that ensures reliable protection of the rights of personal data subjects. The text of the Code and a list of its signatories are posted on the Personal Data Portal of the Authorized Body for the Protection of the Rights of Personal Data Subjects in the "Code of Good Practices" section. According to the specified document, the provisions of the Code of Good Practices may be applied by the Parties within the territory of the Russian Federation as business conduct and practices and do not extend to their relationships established within the territory of foreign states. A corresponding application must be submitted to join/adopt the Code.

The Federal Service for Surveillance in the Sphere of Communications, Information Technology, and Mass Media also maintains an information and entertainment website for children and adolescents aimed at studying issues related to protecting the rights of personal data subjects. Information materials for children are posted on the website, which can be used both within school lessons on the topic of personal data and simply as interesting and educational information.

Also, according to Article 22 of the Personal Data Law, before starting personal data processing, an operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out personal data processing.

Thus, the development of a personal data processing policy and the filing of a notification with Roskomnadzor regarding the commencement of personal data processing are extremely important.

Requirements for Online Sales

Currently, an increasing number of goods/works/services are sold via the Internet. When making a corresponding order, website users effectively enter into legal relations with the seller/contractor/executor. To regulate all details of the legal relationship and prevent possible conflicts, it is necessary to place a public offer on the website and obtain the user-customer's consent to the terms of the offer. According to Articles 435 and 437 of the Civil Code, an offer is a proposal addressed to one or more specific persons that is sufficiently definite and expresses the intention of the person making the proposal to consider itself as having concluded a contract with the addressee by whom the proposal is accepted. Advertising and other proposals addressed to an indefinite circle of persons are considered invitations to make offers, unless otherwise explicitly stated in the proposal. A proposal containing all essential terms of the contract, from which the will of the person making the proposal to conclude a contract on the terms specified in the proposal with anyone who responds is apparent, is recognized as an offer (a "Public Offer").

The conclusion of offer contracts and the development of their terms are important for both website owners and their users. For example, in one case, the court took the position of the website user and overturned the decisions of lower courts that had refused inclusion in the register of creditors' claims on the grounds of the absence of a contract in simple written form, since the creditor had concluded the contract by agreeing to the terms of a public offer.

Also, when interacting with consumers (selling goods/works/services for personal, family, household, and other needs) via a website, according to Article 10 of the Law of the Russian Federation No. 2300-1 dated February 07, 1992, On Protection of Consumer Rights (the "Consumer Protection Law"), information about goods (works, services) must mandatorily contain the following basic information:

• the name of the technical regulation or other designation established by the legislation of the Russian Federation on technical regulation and testifying to the mandatory confirmation of product compliance;
• information about the main consumer properties of the goods (works, services);
• the price in rubles and conditions for purchasing goods (works, services);
• the warranty period, if established;
• rules and conditions for the effective and safe use of goods (works, services);
• the service life or shelf life of goods;
• the address (location), corporate name (name) of the manufacturer (executor, seller), authorized organization, or authorized individual entrepreneur, importer;
• information about the mandatory confirmation of compliance of goods (works, services);
• information about the rules for selling goods (performing works, providing services).

Thus, the specified information must be placed on websites working with consumers. Otherwise, in accordance with Article 12 of the Consumer Protection Law, the absence of information or the presence of untrue information about a product is equated to defects in said product. In this connection, the consumer has the right to present the requirements provided for by Clauses 1 – 4 of Article 18 of the Consumer Protection Law:

• to eliminate product defects free of charge or reimburse the costs for their correction by the consumer or a third party; to commensurately reduce the purchase price;
• to replace it with a product of a similar brand (model, article); to replace it with the same product of another brand (model, article) with a corresponding recalculation of the purchase price;
• to refuse to perform the sale and purchase contract and demand a refund of the amount paid for the product;
• to demand full compensation for losses caused to them as a result of the sale of a product of inadequate quality.

In addition to liability to the consumer, according to Part 2 of Article 14.7 of the CAO RF, misleading consumers regarding the consumer properties or quality of a product (work, service) entails the imposition of an administrative fine: from 3,000 to 5,000 rubles for citizens; from 12,000 to 20,000 rubles for officials; and from 100,000 to 500,000 rubles for legal entities.

In addition to compliance with the above requirements, as a general rule of Clause 2 of Article 5 of Federal Law No. 54-FZ dated May 22, 2003, On the Application of Cash Register Equipment during Settlements in the Russian Federation (the "KKT Law"), a cash receipt is issued to buyers when making settlements at the time of payment for goods and services. For non-cash payments, the receipt must be generated no later than the business day following the day the settlement was made, but no later than the moment the goods are transferred. At the same time, it is permitted to send the receipt to the buyer in electronic form to a subscriber number, transfer it on paper together with the goods, or hand it over during the first direct interaction between the buyer and the seller without sending an electronic receipt to the buyer (Clause 5.3 of Article 1.2 of the KKT Law). Thus, the seller's obligation to provide the consumer with a cash or sales receipt is also recognized as fulfilled when sending the receipt using electronic and other technical means. As explained by the Federal Tax Service of Russia, an organization or individual entrepreneur has the right to purchase KKT or lease it.

In accordance with Part 2 of Article 14.5 of the CAO RF, the non-application of cash register equipment in cases established by federal laws, or the application of cash register equipment that does not meet established requirements or is used in violation of the procedure and conditions for its registration and application, as well as the refusal to issue a document (sales receipt, slip, or other document confirming receipt of funds for the relevant product (work, service)), entails: a warning or the imposition of an administrative fine from 1,500 to 2,000 rubles for citizens; from 3,000 to 4,000 rubles for officials; and from 30,000 to 40,000 rubles for legal entities.

Based on the foregoing, when carrying out sales of goods/works/services via websites, it is necessary to comply with a complex of legal norms regulating both contractual relations with buyers and the specifics of conducting online payments.

Anti-Corruption Regulation

As the Ministry of Labor of Russia notes, standards of fair and ethical behavior implemented within anti-corruption compliance procedures are becoming increasingly relevant for business.

The areas of activity potentially associated with the highest corruption risks primarily include the following:

• procurement of goods and services for the organization's needs;
• obtaining and leasing out property;
• sale of property, including non-core assets;
• any functions involving the organization's financing of the activities of individuals and legal entities (for example, providing loans, sponsorship, etc.).

In order to successfully implement anti-corruption norms, the Russian Union of Industrialists and Entrepreneurs, the Chamber of Commerce and Industry of the Russian Federation, the "Delovaya Rossiya" All-Russian Public Organization, and the "OPORA Russia" All-Russian Public Organization for Small and Medium-Sized Entrepreneurship developed the text of the Anti-Corruption Charter of Russian Business and approved the Regulations governing the conditions and procedure for joining the Anti-Corruption Charter. According to the specified document, companies develop anti-corruption measures taking into account the specifics of their activities and factors such as company size, type of activity, set of risks and geography of the company's activities, the current situation, and corporate culture features. Companies use internal procedures and tools that allow for the improvement of anti-corruption programs, including "feedback" mechanisms, prevention and resolution of conflicts of interest, and consideration of complaints.

Current Russian legislation does not establish an obligation to post an anti-corruption policy on the official websites of organizations. However, to ensure transparency of company activities and form "feedback" when interacting with website visitors, the development and publication of an anti-corruption policy on the website is recommended.

It is also important to remember that there are currently legal acts of an extraterritorial nature. In particular, these include the FCPA (Foreign Corrupt Practices Act) and the Bribery Act. These legal acts also apply to any foreign organizations that carry out their activities fully or partially within the territory of the United Kingdom and the USA. Significant fines are imposed for violations of the anti-corruption legislation of these countries. In this regard, it is not mandatory for a company to be registered within the territory of these states.

Furthermore, the International Chamber of Commerce (ICC) has developed a model anti-corruption clause for inclusion in contracts, on the basis of which the parties undertake to comply with ICC rules on combating corruption and develop an anti-corruption compliance program.

Thus, despite the absence of an obligation to include an anti-corruption clause in contracts, such inclusion is recommended in concluded contracts (including the text of a public offer), especially when the company operates in areas of activity potentially associated with the highest corruption risks.

Specific Restrictions on Information Access on Websites

Depending on the profile of a particular organization's activities, as well as the content placed on its website, some restrictions on access to website information or compliance with specific requirements for website content may be required. Let us provide some examples.

For example, the provision of telematic communication services with access to a data transmission network using a subscriber line is carried out on the basis of a contract concluded in writing. To conclude a contract providing access to a data transmission network using a subscriber line, a person intending to conclude the contract submits an application for the conclusion of the contract to the communication operator.

At the same time, when this requirement is not met, courts do not accept the arguments of the organization providing communication services regarding compliance with the requirements of civil legislation on the form of the transaction in the form of a public offer for the provision of telematic communication services. In the opinion of the courts, this does not testify to compliance with the above requirements.

Also, according to Clauses 4 and 5 of Article 6 of the Law on Advertising, in order to protect minors from abuse of their trust and lack of experience, advertising is not permitted to create an impression among minors that possession of the advertised product puts them in a preferred position over their peers or to form an inferiority complex in minors who do not possess the advertised product.

In particular, the control authority identified a violation of these norms in the advertising of a residential complex. It was established that the semantic load of the advertising text: "Do your children play like this? And ours will play like this. Elite house next to a water park in the Pioneersky residential complex" and a visual sequence depicting smiling children, in the event of viewing by the latter, may create a sense of superiority over their peers, just as it may form an inferiority complex in minors not living in the "Pioneersky" residential complex.

Federal Law No. 436-FZ dated December 29, 2010, On Protection of Children from Information Harmful to Their Health and Development, establishes that information prohibited for distribution among children includes information: encouraging children to commit actions posing a threat to their life and (or) health; capable of causing children to want to consume narcotic drugs, psychotropic and (or) intoxicating substances, tobacco products, nicotine-containing products, alcohol and spirit-containing products, or take part in gambling; justifying or justifying the admissibility of violence and (or) cruelty; denying family values; justifying illegal behavior; containing obscene language, pornographic information; about a minor victim of illegal actions, allowing for the direct or indirect identification of such a minor. This Law also establishes a number of age restrictions on access to certain types of information. In this regard, when filling a website, additional analysis is required for compliance with the requirements of this Law and, if necessary, restricting access to information for minors or children of certain age categories.

It is also important to note that Article 21 of the Law on Advertising establishes an explicit ban on advertising alcoholic products on the Internet.

Furthermore, in accordance with Clause 8 of Article 7 of the Law on Advertising, advertising of tobacco, tobacco products, tobacco items, nicotine-containing products, smoking accessories, including pipes, cigarette paper, lighters, as well as devices for consuming nicotine-containing products and hookahs, is not permitted.

According to Clause 3 of Part 5 of Article 5 of this Law, a ban is established on demonstrating the processes of smoking tobacco or consuming nicotine-containing products and consuming alcoholic products.

These restrictions are also mandatory for compliance when forming website content.

In this article, we have presented the main legislative requirements for websites. However, depending on the field of activity of the organization or individual entrepreneur, additional requirements for the website may be established.

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References

1. Letter of FAS Russia dated June 20, 2018 No. AD/45557/18 On the Assessment of an Indefinite Circle of Persons in Advertising.
2. Letter of FAS Russia dated September 25, 2019 No. AK/83509/19.
3. Letter of FAS Russia dated December 21, 2018 No. AK/105192/18.
4. Resolution of the Plenum of the Supreme Arbitration Court of the Russian Federation dated October 8, 2012 No. 58 On Certain Issues of the Practice of Application of the Federal Law On Advertising by Arbitration Courts.
5. Decision of the Tatarstan Directorate of FAS Russia dated May 28, 2021 No. AY-08/6450 in Case No. 016/05/5-526/2021.
6. Ruling of FAS Russia in Case dated June 14, 2018 No. 3-5-6/00-08-18.
7. Decision of the Chelyabinsk Directorate of FAS Russia dated May 22, 2020 in Case No. 074/05/27-242/2020.
8. Decision of the Tatarstan Directorate of FAS Russia dated March 24, 2021 No. AY-08/3412 in Case No. 016/05/5-199/2021.
9. Decision of the Omsk Directorate of FAS Russia dated March 13, 2019 No. 06-06/10-2019 in Case No. 055/05/05-99/2019.
10. Decision of the Volgograd Directorate of FAS Russia dated February 28, 2019 in Case No. 18-03-5/7-02/847.
11. Letter of FAS Russia dated June 25, 2013 No. AK/24455/13 On Advertising SMS Messages.
12. Ruling of the Supreme Court of the Russian Federation dated September 11, 2020 No. 305-ES20-11672 in Case No. A40-79044/2019.
13. What are cookies? // RBC Tenders.
14. General Data Protection Regulation (GDPR) of the European Union.
15. Policy for the Protection of Personal Data of Individual Clients of FSUE "Russian Post" and subsidiaries of FSUE "Russian Post" registered in the European Union, approved by Order of FSUE Russian Post dated February 21, 2019 No. 73-p.
16. Letter of the Ministry of Communications of Russia dated August 28, 2020 No. LB-S-074-24059 On Methodological Recommendations (together with Methodological Recommendations for General Education Organizations on Personal Data Processing).
17. Resolution of the Presidium of the Supreme Arbitration Court of the Russian Federation dated October 4, 2011 No. 9951/10 in Case No. A56-59461/2008/z7.
18. Letter of the Federal Tax Service dated May 15, 2017 No. AS-4-20/9012.
19. Recommendations of the Ministry of Labor and Social Protection of the Russian Federation on the Procedure for Conducting Corruption Risk Assessments in an Organization dated September 19, 2019.
20. Methodological Recommendations for the Development and Adoption of Measures by Organizations for Preventing and Combating Corruption, approved by the Ministry of Labor and Social Protection of the Russian Federation on November 8, 2013.
21. ICC Anti-Corruption Clause.
22. Resolution of the Supreme Court of the Russian Federation dated October 5, 2015 No. 304-AD15-11556 in Case No. A03-24644/2014.
23. Decision of the Khabarovsk Directorate of FAS Russia dated March 12, 2019 in Case No. 04-5/24.