Informational Mailing Rules
version dated March 20, 2026
1. General Provisions
1.1. These Rules determine the procedure by which LLC “GVA” sends informational and advertising messages to users of the website https:/mil-team.com/, related pages and forms, as well as to persons who have provided separate prior consent to receive such messages.
1.2. The Operator is Limited Liability Company “GVA” LLC “GVA”, OGRN 1197746596630, INN 7708360980, KPP 770801001, address: 107140, Moscow, 1st Krasnoselsky Lane, 3, basement/premises/room/office 1/I/75/3g, email address: info@mil-team.com.
1.3. These Rules shall apply in conjunction with:
- the Personal Data Processing Policy;
- the Consent to Receive Informational and Advertising Messages;
- the User Agreement.
1.4. These Rules do not replace the procedure for sending responses to a user’s direct request, materials requested by the user, responses to an application, job application, talent pool questionnaire, or other messages that do not constitute advertising within the meaning of the laws of the Russian Federation.
2. Types of Messages
2.1. Informational messages means messages about company news, research, cases, materials, vacancies, events, career opportunities, and other updates of the Operator that are not primarily aimed at generating or maintaining interest in the Operator’s goods, works, services, or offers as an object of advertising.
2.2. Advertising messages means messages aimed at generating or maintaining interest in the Operator’s activities, services, products, projects, and offers, as well as promoting them on the market.
2.3. Messages may be one-time, targeted, or occasional. The Operator does not carry out mandatory regular periodic mailings, unless otherwise expressly stated when obtaining the relevant consent.
2.4. Sending materials, presentations, responses to requests, or arranging a call or meeting upon the user’s direct request shall not, in itself, be deemed an advertising mailing, provided that the relevant message is connected with the user’s request and does not go beyond it without separate consent.
3. Legal Grounds, Consent, and Evidence
3.1. Advertising messages, as well as other messages that by their content constitute advertising or are aimed at generating or maintaining interest in the Operator’s activities, products, services, or projects, shall be sent only where the recipient has provided separate prior consent.
If the Operator cannot confirm that such consent has been obtained, the relevant advertising communication must not be sent.
3.2. Consent to receive advertising messages shall be provided only by means of an active action by the user in the relevant form. Pre-ticked checkboxes are not permitted. Consent to receive advertising messages must not be combined with consent to personal data processing for the main application, vacancy, talent pool, the user’s choice regarding cookies that are not strictly necessary, or mere acceptance of the User Agreement.
3.3. The Operator records the fact of obtaining consent and has the right to store information on the version of the consent text, the date and time it was obtained, the page or form through which it was provided, selected topics and communication channels, technical metadata including IP address, browser information, browser identifier/user-agent, information on the user’s device allowing confirmation of the user’s expression of will, as well as information on subsequent refusals, changes of choice, and termination of communication.
3.4. Consent must be worded in such a way that the recipient, the specific advertising distributor, the types of messages, and the communication channels covered by the consent can be unambiguously determined.
4. Communication Channels
4.1. Messages shall be sent only through those communication channels that the user has personally indicated and for which the user has provided separate consent.
4.2. Communication channels may include an email address, telephone calls, and messages in messengers, including Telegram, where the relevant channel is provided for by the form and selected by the user.
4.3. The use of any other communication channel not indicated by the user when providing consent shall not be permitted until separate consent for such channel has been obtained.
5. Data Used for Sending Messages
5.1. For the purpose of sending informational and advertising messages, the Operator uses the minimum necessary scope of data, which may include:
- name;
- email address;
- telephone number;
- username/identifier in Telegram or another messenger;
- information on topics and communication channels selected by the user;
- information on the fact of granting, changing, and withdrawing consent.
5.3. The Operator does not carry out cross-border transfer of personal data in connection with sending messages.
6. Frequency and Content
6.1. The Operator shall send messages only to the extent reasonably necessary for the relevant topic, communication channel, and nature of interaction with the user, and shall not allow intrusive repetition of messages.
6.2. Unless otherwise follows from the user’s request or the nature of the communication, messages shall be sent moderately, subject to valid consent, and only in connection with the topic and communication channel selected by the user. The specific frequency is not fixed and shall be determined by the nature of the request, event, vacancy, or offer.
6.3. Messages must not contain inaccurate information, mislead the recipient, or violate the requirements of the laws of the Russian Federation on advertising, personal data, or other applicable laws and regulations.
6.4. Calls and messages shall not be made or sent at night according to the recipient’s local time, unless otherwise expressly follows from the recipient’s request or prior arrangement with the recipient.
7. Unsubscription
7.1. In each channel where technically possible, the Operator shall provide a clear and accessible way to opt out of further messages.
7.2. The user has the right to opt out of:
- all messages at once;
- specific topics;
- specific communication channels.
7.4. Refusal to receive informational and advertising messages shall not affect the ability to use the website, submit requests, job applications, talent pool questionnaires, or other primary requests to the Operator.
8. Contractors
8.1. For the purpose of sending messages, the Operator has the right to use external communication services, mailing and other communication platforms, and to engage other persons involved in personal data processing for the purposes of sending messages, provided that such persons are engaged on a lawful basis and in compliance with personal data protection requirements.
8.2. For the purpose of sending messages, the Operator has the right to use the website platform, customer relationship management systems CRM systems, corporate email, messaging services, messengers, call tracking services, and other communication tools, as well as to engage individuals performing work or rendering services under civil-law contracts, provided that such persons participate in personal data processing on behalf of the Operator on a lawful basis.
8.3. If such services or persons participate in personal data processing for the purposes of sending messages, they shall be subject to the provisions of the Operator’s Personal Data Processing Policy, including requirements on localization, confidentiality, personal data security, and the absence of cross-border transfer within the declared processing model.
9. Retention Period
9.1. Contact details and information on consents and refusals to receive messages shall be stored until consent is withdrawn, the relevant communication is terminated, or for the period necessary to confirm the lawfulness of communication and protect the Operator’s rights.
9.2. Evidence of obtaining consent, information on changes of choice, and refusal to receive messages after termination of the relevant communication may be stored, as a rule, for up to 3 years, unless a longer period is required due to a specific dispute, inspection, or other lawful ground.
9.3. The Operator shall immediately cease sending advertising messages through the relevant channel after receiving the recipient’s refusal to continue receiving such messages.
9.4. Upon expiry of the retention period, the relevant information shall be deleted, depersonalized, or further stored only to the extent and for the period necessary in accordance with the laws of the Russian Federation or for protection of the Operator’s rights and legitimate interests in a specific situation.
9.5. If, after withdrawal of consent, retention of personal data is no longer required for the purposes of sending messages and there are no other lawful grounds for its processing, the Operator shall cease such processing and ensure deletion or destruction of the relevant personal data within a period not exceeding 30 days from the date of receipt of the withdrawal.
10. Final Provisions
10.1. The Operator has the right to amend these Rules by publishing a new version on the website. The new version shall apply from the moment of its publication, unless otherwise expressly stated therein.
10.2. The current version of these Rules must remain permanently publicly available on the website.
