EPAM advised a large e-sports brands in connections with the launch of an Internet platform for Russian users, fans of a professional e-sports team. The platform provides for a loyalty program for its registered users, which gives rewards for being part of the fans’ community. It allows its users to exchange points for goods or services offered in a reward shop and acquire rewards through participating in various experiences.
EPAM team provided the client with comprehensive advice on compliance with Russian legislation when launching the platform, in particular, on regulatory, advertising, contractual, tax, customs, currency control, data protection and some other issues. We also advised on adaptation of policies regulating the use of platform services and cookies to the requirements of Russian law.
One of the challenging facts was that the platform assumes access of minors, processing of their personal data and tracking of their activity in social networks. Russian legislation does not regulate in detail the activity of minors on the Internet. In this regard, the assessment of compliance of certain provisions of the platform's local regulations is significantly complicated by the possibility of their different interpretation by authorities. An additional complication is the limited legal capacity of minors, coupled with the lack of reliable ways to obtain consent to their activities on the Internet from their legal representatives.
EPAM attorneys also provided advice on compliance with Russian data localization rule, requiring processing personal data of Russian citizens with use of databases in Russia, and on processing of website cookies. Work on this project is remarkable as liability for violation of data localization requirement was recently increased and the regulator is paying more and more attention to compliance with this requirement by foreign operators. Requirements to the use of website cookies is also a very specific area of law. Website cookies were quite recently recognized as personal data. At current moment, there are no special norms regulating processing of cookies with consideration of their
EPAM team working on the project consisted of Counsels Elena Agaeva, Pavel Sukholinskiy, Alexey Karchiomov, and Senior Associate Olga Morozova under the lead of Partner, Head of European Desk Ilona Zekely.