Privacy notice, consent, and contract: different legal bases

On data-collection pages, provide a notice covering controller, purposes, data categories, operations, retention, recipients, rights, and contacts.

Align the privacy notice with the actual data map rather than copying a generic template. Place a short plain-language explanation and the current-version link beside each form. Contacts, recipient descriptions, and rights-request methods must work in practice. Before publication, a responsible specialist should check the document against current requirements and the real infrastructure.

When consent is used, it should be specific, informed, and demonstrable. Since 1 September 2025, Russian law requires personal-data consent to be documented separately from other information and documents the person confirms or signs. Mandatory registration should also remain separate from optional marketing.

A consent flow should identify the specific purpose, data categories, operations, duration, and withdrawal method to the required extent. Since 1 September 2025, it must be documented separately from other information or documents the person confirms or signs. Avoid preselected boxes for optional purposes and do not block the core service when marketing is declined. Evidence should link the user, notice version, timestamp, and action without storing an unnecessary full-page capture or session secrets.

Data objectively required for account, payment, service delivery, and support should be separated from optional purposes.

For contract performance, create an operation-to-necessity table covering account creation, payer checks, access delivery, support, documents, and debt handling. Include only objectively required fields. Profiling, marketing, and optional analytics need separate assessment. After contract termination, some records may remain under another applicable basis, which should be documented explicitly.

Store document version, acceptance time, and UI context without secrets. Reassess the legal basis after material changes.

A version register should store effective date, text checksum, affected purposes, and notification plan. On withdrawal, the system identifies related processes, stops only the corresponding operations, and confirms the outcome. Do not simply erase the consent record because minimal evidence of prior processing may be needed. Determine exact content and periods under current requirements with responsible specialists.