Terms used in this document: INN — taxpayer identification number; OGRNIP — primary state registration number of an individual entrepreneur; OGRN — primary state registration number; OOO — limited liability company; IP address — the network address from which a request originates; cookies — small records that a website stores in the browser.
1. General provisions and information about the Controller
1.1. The personal data Controller is Individual Entrepreneur Andrei Viktorovich Svirin:
- INN: 772872317733;
- OGRNIP: 322774600176722;
- correspondence address: P.O. Box 15, Moscow, 117647;
- email for personal data matters: privacy@jurist.moscow;
- website: https://jurist.moscow/.
1.2. Application means the Client's inquiry through the Website, email, phone or another agreed channel describing a legal question. An Application does not itself constitute acceptance of the Offer or oblige the Service Provider to accept the assignment.
1.3. Invoice-Order means a paper document, electronic document or agreed communication from the Provider setting out the individual terms of the assignment: the legal actions involved, source materials, price, payment arrangements, timeframe and form of the deliverable. Once accepted, it forms part of the contract.
2. Legal grounds and principles of processing
2.1. Personal data is processed in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter the Personal Data Law) and other applicable regulatory legal acts of the Russian Federation. The terms "personal data", "personal data processing", "controller", "provision of personal data", "depersonalization of personal data" and "destruction of personal data" are used with the meanings established by Article 3 of that Law.
2.2. Personal data is processed on a lawful and fair basis and is limited to achieving specific, predetermined and lawful purposes. The content and volume of the personal data processed must correspond to the stated processing purposes; excessive processing and processing incompatible with the purposes of the initial collection are not permitted.
2.3. Visiting the Website does not, in itself, constitute an expression of consent to the use of optional analytics tools. Consent to personal data processing in connection with the submission of an inquiry is given separately from consent to analytics and does not extend to advertising mailings or advertising calls.
3. Purposes, scope of data and grounds for processing
3.1. Consideration of inquiries and feedback
3.1.1. The purposes of processing are to receive and consider the Applicant's inquiry, clarify the circumstances relating to the inquiry, prepare and send a response, and provide a preliminary consultation and a cost estimate for the requested services. Inquiries are accepted through forms on the Website, by telephone, by email, and through private messages in messengers and social networks.
3.1.2. Data processed comprise the name, or surname, given name and patronymic to the extent supplied by the Applicant; phone number; email address; messenger or social network identifier or username; preferred contact method; inquiry text; information provided by phone; information about the assignment's subject; and personal data in documents, files and subsequent correspondence supplied by the Applicant, solely to the extent necessary to consider the inquiry.
3.1.3. When an inquiry is submitted through a form on the Website, the URL of the submission page, date and time, inquiry identifier and information about the consent expressed are recorded for the purposes of registering and considering the inquiry, checking that it was submitted correctly and confirming the circumstances of its submission. The notification to the Controller includes the IP address of the connection to the server, browser and device information transmitted by the browser, language settings, the time from preparation of the protected form to submission according to the server clock, and the approximate time from opening the current page to submission, if reported by the browser. This information does not establish the sender's identity or determine the full duration of the visit to the Website. Navigation between pages is not tracked on the basis of consent for an inquiry.
3.1.4. Legal grounds for processing: the Applicant's consent, the receipt of which is confirmed by the Controller — clause 1 of part 1 of Article 6 of the Personal Data Law; where an inquiry is made for the conclusion of an agreement at the initiative of the personal data subject — clause 5 of part 1 of Article 6 of that Law, to the extent necessary to conclude the agreement. Separate consent is not required for such necessary processing. A call or the sending of a message does not, in itself, constitute automatically obtained consent to data processing for other purposes.
3.1.5. Communication with the Applicant takes place using the contact details provided by the Applicant through communication channels agreed with the Applicant, solely on matters relating to the inquiry received. Information obtained during subsequent communication is subject to the processing grounds, retention periods and deletion procedure established by this Policy for the relevant purpose.
3.1.6. Attached files are used for familiarization, clarification of the circumstances of the inquiry, preliminary assessment and preparation of a response. The processing of materials necessary to provide a service is carried out on the appropriate independent ground. The initial submission does not authorize the publication of files, their use for advertising or their transmission to analytics. The conditions for the lawful acquisition and transfer of materials are defined in the Terms for the Transfer and Use of Materials.
3.2. Document authenticity check
3.2.1. The purposes of processing are to consider a request to examine the submitted document and accompanying materials, preliminarily assess their content and send a response to the Applicant within the requested service.
3.2.2. Data processed: the Applicant's contact details, identifying details of the document being checked, its copy and other information necessary to carry out the check.
3.2.3. The legal ground for processing the Applicant's personal data is the Applicant's consent or another applicable ground provided for by the Personal Data Law. Third-party personal data contained in a document may be processed where an independent lawful ground exists in respect of the persons concerned. An agreement with the Applicant is not a sufficient ground for processing any and all personal data of third parties.
3.2.4. When communicating the check result, third-party personal data may be disclosed to the Applicant only where there is an appropriate lawful basis.
3.3. Conclusion and performance of an agreement
3.3.1. Processing is intended to agree terms and provide legal services, analyze documents, prepare consultations, submissions and other agreed results, arrange payments and communicate with the Client.
3.3.2. Data processed comprise surname, given name and patronymic; contact details, including an identifier or username in the agreed communication channel; addresses; order-related information provided by phone or correspondence; information about the assignment's subject; documents and materials needed for the services; and payment details. Where a representative is involved, their details and documents confirming authority are processed.
3.3.3. Passport details and other identifying information are requested solely where they are necessary to perform a specific action or draw up the relevant document.
3.3.4. Legal grounds for processing: clause 5 of part 1 of Article 6 of the Personal Data Law — in respect of a person who is a party, beneficiary or guarantor under the agreement, and when an agreement is concluded at the initiative of the personal data subject; clause 2 of part 1 of Article 6 — to fulfill obligations provided for by law. An independent applicable ground is determined for the data of representatives and other persons.
3.4. Fulfillment of statutory obligations
3.4.1. The purposes of processing are to maintain records required by legislation, document payments and comply with lawful demands and requests from authorized authorities.
3.4.2. The scope of the data processed is determined by the content of the relevant obligation established by the legislation of the Russian Federation.
3.4.3. Legal ground for processing: clause 2 of part 1 of Article 6 of the Personal Data Law and the legislative requirements establishing the relevant obligation.
3.5. Consideration of claims and protection of rights
3.5.1. The purposes of processing are to consider claims, resolve disputes, exercise and protect the Controller's rights and legitimate interests, and confirm the content of communications and the existence of a legal ground for personal data processing.
3.5.2. Scope of the data processed: documents and correspondence relating to the relevant dispute, necessary information about communications, and minimal records confirming receipt of consent.
3.5.3. Legal grounds for processing: legislative requirements and clause 7 of part 1 of Article 6 of the Personal Data Law — the exercise of the Controller's rights and legitimate interests, provided that the rights and freedoms of the personal data subject are not infringed.
3.6. Website operation and security
3.6.1. The purposes of processing are to ensure the operation of the Website and inquiry forms, prevent automated and unlawful submissions, identify technical errors and abuse, and retain and apply the visitor's analytics choice.
3.6.2. Scope of the data processed: IP address, date and time of the request, URL of the requested page, technical browser information, session identifier and information about the visitor's choice.
3.6.3. Legal ground for processing: clause 7 of part 1 of Article 6 of the Personal Data Law — ensuring website operation and security and exercising the Controller's rights and legitimate interests, provided that visitors' rights and freedoms are not infringed. This information is not used on this ground for optional analytics or advertising.
3.7. Visit analytics
3.7.1. The purposes of processing are to assess Website traffic, referral sources, page use and Website usability, and to compare the relevant indicators for different periods.
3.7.2. The scope of the data processed is defined in section 6 of the Policy.
3.7.3. Legal ground for processing: clause 1 of part 1 of Article 6 of the Personal Data Law — the visitor's separate consent, expressed through the banner or analytics settings panel on the website.
3.8. Advertising messages by email
3.8.1. The purposes of processing are to promote the Controller's services through direct email contact, maintain subscriptions and implement the settings selected by the subscriber.
3.8.2. Data processed comprise email address, subscription identifier, consent records, subscription status and opt-out information. When subscribing, technical form submission information is also recorded: the IP address connecting to the server, browser and device information (User-Agent), browser language (Accept-Language), approximate time between opening the current page and submitting it as reported by the browser, and time between preparation of the secure form and submission according to the server clock. This information records submission circumstances and checks technical failures and unauthorized submissions; it is not used for behavioral analytics or advertising profiling and does not establish identity or time spent on the entire Website. Inquiry materials and assignment information are not used for this purpose.
3.8.3. The legal ground for processing is the personal data subject's separate prior consent in accordance with clause 1 of part 1 of Article 6 and part 1 of Article 15 of the Personal Data Law. Advertising may be sent where the recipient's prior consent exists in accordance with part 1 of Article 18 of Federal Law No. 38-FZ of 13.03.2006 "On Advertising".
3.8.4. Opting out of an advertising subscription is not a ground for refusing to consider an inquiry, conclude an agreement or provide services. Processing for advertising purposes and the sending of advertising messages cease immediately at the request of the personal data subject or recipient.
3.8.5. When the unsubscribe form is submitted, the email address and minimal information about the opt-out are recorded. Technical information about that submission may additionally be recorded: the IP address of the connection to the server, browser and device information (User-Agent), browser language (Accept-Language), the approximate time from opening the current page to submission, and the time from preparation of the protected form to submission according to the server clock. This information is used to check the circumstances of the opt-out, technical failures and unlawful submissions; the Controller receives it in an internal notification. The grounds for processing information about the opt-out are compliance with statutory obligations to cease advertising and processing for advertising purposes; for technical information, the grounds are ensuring form security and protecting legitimate interests while respecting the rights and freedoms of the personal data subject (clauses 2 and 7 of part 1 of Article 6 of the Personal Data Law, as applicable). This processing is not based on the advertising consent being withdrawn and is not used to continue advertising or for behavioral analytics.
4. Personal data processing procedure and involvement of third parties
4.1. Depending on the purpose and legal ground, the Controller performs the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), blocking, deletion and destruction. Processing is carried out using automated means, without such means, or by a combination of both.
4.2. Access to personal data is granted solely to persons who require such access to perform the relevant functions, within the necessary scope of data.
4.3. The Controller uses technical infrastructure and email facilities to host the Website and deliver enquiries. Access to personal data by engaged parties is limited by the relevant task, contract and applicable legislation.
4.5. Yandex Metrica, provided by YANDEX LLC, may be used for visitor analytics. The visitor's choice is saved using the Website's tools. The counter is loaded only with consent and after data retention settings have been checked.
4.6. Where personal data processing is entrusted to a third party, the relevant instructions are formalized in compliance with the requirements of part 3 of Article 6 of the Personal Data Law. Data is provided to such persons solely to the extent necessary to carry out the relevant instructions. The involvement of third parties does not release the Controller from statutory obligations to personal data subjects.
4.7. During contract performance, personal data may be provided to agreed specialists, delivery services, credit institutions and other participants to the extent necessary for the relevant service and where an applicable legal basis exists.
4.8. Personal data is provided to courts and state authorities in the cases and in accordance with the procedure provided for by the legislation of the Russian Federation.
4.9. Providing Applicants' contact details to third parties for their independent advertising mailings without a separate lawful ground is not permitted.
4.10. When collecting personal data of citizens of the Russian Federation, the Controller ensures compliance with the requirements of part 5 of Article 18 of the Personal Data Law concerning the use of databases within the Russian Federation.
4.11. Before beginning a cross-border transfer, the Controller complies with the requirements of Article 12 of the Personal Data Law and provides personal data subjects with the necessary information about such processing. Consent to analytics does not, in itself, override localization and cross-border transfer requirements.
5. Personal data processing and retention periods
5.1. Personal data relating to inquiries that do not result in an agreement, including correspondence and attachments, is processed and retained for the period necessary to consider the inquiry, but no longer than 90 calendar days from the date of the last substantive message or telephone conversation relating to the inquiry concerned. If there is no subsequent communication, the period is calculated from the date the inquiry is received. The sending of automatic messages and service notifications does not change the start of this period.
5.2. Personal data in documents relating to concluded agreements is retained for the period necessary to perform the agreement and for the statutory retention periods for the relevant documents. After those periods expire, further retention is permitted solely where an independent lawful ground exists.
5.3. The retention period for ordinary technical security logs is no longer than 30 calendar days. Information relating to a specific incident may be retained beyond that period solely for the time necessary to investigate the incident or protect rights and legitimate interests.
5.4. A minimal record confirming receipt of consent may be retained on an independent lawful ground for no longer than three years from the date consent is expressed, if such retention is necessary to confirm the lawfulness of processing or protect rights and legitimate interests. The record of consent to processing an inquiry includes contact details that allow the record to be matched to the inquiry, the inquiry identifier, submission date and time, URL of the submission page, the choice made and information about the version of the consent. The full inquiry text and attachments are not included in that record.
5.5. For consent to analytics, the minimal record includes the choice made, the date and time it was expressed, information about the version of the consent and a necessary technical identifier. This record is not linked to the visitor's name, telephone number or email address.
5.6. The processing and retention period for analytics data that allows visits to be associated with a particular visitor or browser is limited to the period necessary to analyze and compare indicators for different periods and may not exceed three years from the date the relevant data is collected. At the end of this period, the data must be deleted or converted into aggregate statistical indicators that exclude the possibility of identifying a particular visitor. If the purpose of processing is achieved earlier or consent is withdrawn, the provisions on early termination of processing apply. Aggregate indicators that do not allow a particular visitor to be identified may be retained for statistical purposes.
5.7. The specifics of processing and the data retention periods within Yandex infrastructure are defined by the Terms of Use of the Yandex Metrica Service (https://yandex.ru/legal/metrica_termsofuse/ru/), section 8 of the Yandex Privacy Policy (https://yandex.ru/legal/confidential/ru/) and the documentation for the relevant functions. The three-year maximum period established by the Controller limits processing for the stated purpose and does not change the service terms. The Controller ensures compliance with this maximum period by deleting the data or converting it into aggregate statistical indicators that exclude the possibility of identifying a particular visitor. Reference to the service terms does not override the retention limit established by this document.
5.8. Webvisor recordings are stored in the service for 15 days, including the current day, in accordance with Yandex documentation: https://yandex.ru/support/metrica/ru/webvisor/requirements.html. This period applies separately from the overall maximum retention period for analytics data. The cookie lifetimes specified in section 6 of the Policy do not determine the data retention periods on the service's servers.
5.9. When the processing purpose is achieved, the established retention period expires or the legal ground ceases to exist, personal data must be deleted or destroyed unless legislation or another applicable lawful ground provides for its further retention. These requirements apply to all copies of data in the information systems and email used. In the cases provided for by law, the Controller also ensures that persons acting on the Controller's instructions cease processing and destroy the data.
5.10. Upon receipt of a withdrawal of consent, processing carried out on the basis of that consent ceases. If retention of the personal data is no longer required for the purposes of processing and no other lawful ground exists, the Controller ensures its destruction within the period provided for by part 5 of Article 21 of the Personal Data Law: as a general rule, no more than 30 days from receipt of the withdrawal, subject to the exceptions established by that provision.
5.11. The processing period for advertising subscription data is no longer than three years from the date the consents are expressed in the separate subscription form and is limited to the actual need for processing for the stated purpose. An email confirming the address is not sent. If either consent is withdrawn or the subscription is terminated, processing for advertising mailings ceases early. After the subscription is terminated, minimal information about the consents and opt-out may be retained on an independent lawful ground for no longer than three years, solely to confirm the lawfulness of processing, implement the advertising opt-out or protect rights and legitimate interests, provided that the rights and freedoms of the personal data subject are respected. These periods are rules chosen by the Controller and do not mean that there is a statutory obligation to retain the information for the entire stated period.
5.11.1. It is possible to opt out of advertising and withdraw consent to data processing for advertising mailings through a separate form, via the link in an advertising email or through the Controller's contact details. Only an email address is needed for the form; new consent and confirmation by email are not required. Upon successful submission, the subscription is disabled immediately. The address, subscription and opt-out identifiers, date and time, opt-out method and page, and termination of the subscription are recorded. An internal opt-out notification is sent to the Controller; failure to deliver that notification does not reverse the disabling of the subscription. The minimal record and its email copy are retained within the limits and on the grounds specified in clause 5.11. Technical information from the opt-out notification is retained separately within the limits of clause 5.12. For an address absent from the register, no new subscription or separate long-term opt-out record is created.
5.12. Technical information included in the notification of an inquiry is stored together with it within the period specified in clause 5.1 and is not included in the three-year minimal consent log. When files are transferred, the minimal record may additionally contain the fact of acceptance of the terms for the transfer of materials, a link to those terms and their version, without the contents or names of the files. Files received with an inquiry and their copies must be deleted within the same limits as the inquiry, unless there is an independent lawful basis for retaining them. Ordinary separate technical security logs are stored within the limits specified in clause 5.3. Technical information from the initial submission of a subscription form or an opt-out form, and internal notifications containing such information, including email copies, are stored for no more than 30 calendar days from the date of the relevant submission; they are not included in the minimal consent records retained for up to three years.
6. Use of cookies and web analytics tools
Cookies are small records that the browser stores on the device when the Website is visited and may send to the Website with subsequent requests. They make it possible, for example, to maintain a technical form session and remember the visitor's settings.
Browser local storage (localStorage) is a mechanism for storing data on the device between visits to the Website. Unlike cookies, these records are not automatically sent to the server with each request and do not have a built-in deletion period. The validity period of the choice and the check for its expiration are determined by the Website's code.
6.1. Necessary technologies
6.1.1. Necessary technical tools are used on the Website to ensure the operation of inquiry forms, protect submissions and save visitors' settings.
6.1.2. The FORMSESSID cookie contains the identifier of the technical form session and is used for the operation of the mechanism that protects inquiry submissions. This cookie is not used for visit analytics. The cookie remains valid for the browser session.
6.1.3. The visitor's analytics choice is recorded by the Website in the jm_analytics_choice cookie and the jm-analytics-choice-v1 local storage entry solely to save and apply that choice. The choice is valid for 180 days from the date it is saved. The cookie is assigned the same lifetime. The local entry contains expiry information: after expiry, the choice is no longer applied and the entry is deleted by the Website's code on the next visit or expiry check on an open page. If the Website is not open, the code cannot remotely delete the browser entry; it may remain until the next check or deletion by the user. These entries are not themselves used for behavioural analysis.
6.1.4. The validity period of a cookie in the browser and the retention period of the data associated with it in the information system are separate periods and may differ.
6.1.5. You can change your choice or opt out of analytics using the "Analytics settings" button in the Website footer. The browser's privacy settings also allow you to delete cookies and data for a specific website, including local storage, or configure cookie blocking. To delete local records, select deletion of the site data for jurist.moscow: deleting only cookies may not clear local storage. The names of settings items depend on the browser.
6.1.6. After the Website's data is deleted, the choice panel may appear again. Deleting data does not in itself signify consent to analytics and is not a request to delete previously received data from the systems of the Controller or the analytics service; such requests are sent using the contact details specified in the Policy.
6.1.7. Blocking necessary cookies or browser storage may prevent preparation of the protected form, submission of an inquiry and saving of the choice. Opting out of optional analytics does not prevent viewing the Website or submitting an inquiry.
6.2. Optional analytics
6.2.1. The Yandex Metrica service is enabled and used only after the visitor's separate consent to data processing for analytics purposes has been obtained.
6.2.2. Analytics may involve processing the IP address when the service receives a request, cookie and visit identifiers, technical information about the browser and device, the addresses of pages visited, the date, time and duration of the visit, the referral source and events involving interaction with the Website.
6.2.3. When Webvisor is enabled, the visitor's sequence of actions and the display of the Website's pages are additionally recorded, including navigation, clicks and scrolling.
6.2.4. The Controller ensures that the contents of inquiries, contact details from forms and uploaded documents are excluded from transmission as analytics parameters and from recording by Session Replay (Webvisor). Personal data of the specified nature is not included in page addresses, titles, referral tags or event parameters transmitted to the service.
6.2.5. The main Metrica cookies include:
- _ym_uid — distinguishing visitors, validity period of 1 year;
- _ym_d — date of the first visit, validity period of 1 year;
- _ym_isad — detecting the presence of an ad blocker, validity period of 20 hours;
- _ym_visorc_* — operation of Session Replay (Webvisor), validity period of 30 minutes, when it is used;
- _ym_metrika_enabled — checking the operation of Metrica cookies, validity period of 60 minutes.
6.2.6. Depending on the service's functions, other records in cookies and browser storage may be used. The full list and their purposes are provided in the documentation: https://yandex.ru/support/metrica/ru/general/cookie-usage.
6.2.7. Refusal to give consent to analytics does not limit the ability to use the Website and submit inquiries.
6.2.8. The choice can be changed and consent withdrawn using the "Analytics settings" control available on the Website. After refusal or withdrawal, new analytics requests cease to be sent. Deleting the choice record or using another browser may cause the banner to appear again; these actions do not in themselves constitute an expression of consent.
6.2.9. Requests concerning previously processed data are sent to the Controller at privacy@jurist.moscow. The Controller considers such requests and takes the measures provided for by law, taking into account the possibility of associating the relevant data with the applicant.
6.2.10. Additional information:
- Yandex Metrica terms: https://yandex.ru/legal/metrica_termsofuse/ru/;
- Yandex Privacy Policy: https://yandex.ru/legal/confidential/ru/;
- restrictions on the transmission of identifying data: https://yandex.ru/support/metrica/ru/general/confidential-data.
7. Rights of the personal data subject
7.1. The personal data subject has the right to receive information about the processing of their personal data, to demand its correction, blocking or destruction in the cases provided for by law, to withdraw consent to processing, and to appeal against the Controller's actions or omissions in the manner prescribed by law.
7.2. Inquiries and requests from personal data subjects are accepted at the email address privacy@jurist.moscow or at the correspondence address specified in section 1 of the Policy.
7.3. To identify the inquiry, it is recommended to specify the contact details used when submitting it, the approximate submission date and the inquiry identifier, if available. The Controller may request proportionate verification of the subject's identity or their representative's authority. Requests provided for in Article 14 of the Personal Data Law are subject to the requirements for request contents established by that Article.
7.4. Information about the processing of personal data is provided to the subject or their representative within 10 working days from the date of the inquiry or receipt of the request. Where grounds provided for by law exist, this period may be extended by no more than five working days, with a reasoned notification stating the reasons for the extension being sent.
7.5. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal was received. If the processing of certain data continues on an independent lawful basis, the Controller informs the subject of such processing and its legal basis.
7.6. The subject may seek protection of their rights from the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or in court.
8. Processing of third parties' personal data
8.1. Documents and information submitted through the initial inquiry form must be limited to the extent necessary to consider the inquiry. Before sending materials, it is recommended to remove or conceal excessive passport, financial, medical and other personal data.
8.2. The Applicant's consent applies to their personal data and does not constitute the consent of other persons whose personal data is contained in the submitted materials.
8.3. Where materials are sent by a representative or third parties' personal data is provided, the Controller checks that the relevant authority and legal basis for processing exist. In the absence of a sufficient legal basis, the data is not used to provide services and must be blocked and deleted within the periods provided for by law.
8.4. Special categories of personal data and biometric personal data are processed in compliance with the requirements of Articles 10 and 11 of the Personal Data Law. Expressing consent by checking a box in the inquiry form does not replace written consent in cases where that form is expressly required by law.
8.5. When transferring files, the Applicant separately confirms that they obtained them lawfully and have the right to transfer them to the Controller for review and consideration of the inquiry. Such confirmation does not replace the legal basis for processing other persons' personal data and does not release the Controller from the obligations provided for by law. In case of doubt, the Controller may request documents confirming authority or the basis for the transfer, restrict access and decline to use the materials.
9. Personal data protection and final provisions
9.1. The Controller takes the necessary legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful acts. Such measures include restricting access, ensuring secure data transmission, monitoring retention periods and monitoring compliance with requirements by engaged processors.
9.2. Personal data is destroyed by methods that preclude restoration of its contents in the information system and/or provide for the destruction of physical media containing personal data. The Controller ensures documentary confirmation of destruction in the cases and manner established by legislation.
9.3. The current version of the Policy is posted on the Website with its revision date. Changes to the Policy do not change the scope of consent previously given. If subsequent processing requires new consent, such consent is obtained separately before the relevant processing begins.