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Apple registered with Russian DPA (Roskomnadzor) and complied with Russian personal data localization rules

On 29 December 2018 Roskomnadzor (the “Service”) included Apple Rus LLC in the register of personal data operators. The company’s notification was registered on 25 December 2018.

Apple Rus LLC was registered in Russia on 29 December 2011. The founders of the company are Apple Holding (Netherlands) and Apple Distribution International (Ireland).

According to the register of operators, Apple Rus processes personal data from the date of legal entity registration. Import, export, marketing, resale, retail and online sale of computers, other electronic devices, as well as jewelry are mentioned as the purposes of data processing in the register. The company processes personal data of employees and their families, employees of third-party organizations, representatives of suppliers and consumers of Apple products. Apple Rus has appointed data protection officer and published personal data processing policy.

In accordance with the Federal Law of 27 July 2006 no. 152-FZ On Personal Data (the “Law”) operators are obliged to notify Roskomnadzor of their intention to process personal data before processing, except in cases provided for by law. In July 2014 the Law was amended. According to amended version of the Law data controllers are obliged to provide recording, systematization, accumulation, storage, specification, extraction of personal data of Russian citizens using databases located in Russia (para. 5 Article 18). The amendments entered into force on 1 September 2015.

Apple Rus and have been renting racks to host servers for personal data storage and processing in the IXcellerate data center in Russia since 2015.

Roskomnadzor ordered an investigation of compliance with the Law in respect of Apple Rus on 1 February 2019. Earlier, the Service conducted investigations in respect of U.S. companies Facebook and Twitter.

Nadmitov, Ivanov and Partners Law Firm advises clients on personal data regulation and localization of personal data of Russian citizens in Russia.