152-FZ and business email: what counts as personal data
Russian personal data law (Federal Law 152-FZ) applies to information about an identifiable individual. For outreach, the key question is which addresses identify a person.
Generic vs named addresses
- info@, sales@, zakaz@ - not personal data; they belong to the company (case А40-139096/2022).
- ivan.petrov@company.ru with his name and position - personal data.
Prefer department addresses the company published for contact. They are lawful to use as addresses and usually reach the right team.
Direct marketing (Art. 15)
Using personal data for promoting goods and services by direct contact requires prior consent. Whether this covers employees reached at work in B2B is disputed; the cautious reading is that it does.
Operator duties
- Publish a privacy policy.
- Notify Roskomnadzor before processing.
- Since 1 Jul 2025, record and store Russian citizens' data in databases located in Russia.
- Since 1 Sep 2025, collect consent as a separate document, not buried in terms.
Fines
Under the Code of Administrative Offences as amended on 30 May 2025: processing without legal basis - RUB 150,000-300,000 for companies; without required consent - RUB 300,000-700,000; failure to notify Roskomnadzor - RUB 100,000-300,000.
FAQ
Is a director's name from the state register personal data?
Yes. It is public, but publicity does not remove 152-FZ obligations for further processing.
This article is for information only and is not legal advice. Laws change - check the current wording (consultant.ru, garant.ru) before launching a campaign and consult a lawyer in disputed cases.
You can do all of this yourself in Lidarro. Or hand it over to us as a done-for-you service: we build and check the list, write the copy, run the outreach and hand you the leads. We take on the financial risks, including fines.
Pricing depends on your niche and lead value, so we quote individually.
Read next
- Is cold email legal in Russia? A 2026 guide for B2B sendersWhen a business email to a Russian company is lawful outreach and when it is advertising without consent - with fines up to RUB 1m. Laws, FAS practice and a checklist.
- How to keep cold emails out of the spam folderDomain authentication (SPF, DKIM, DMARC), warm-up, sending volume and content rules that keep business emails in the inbox - including Yandex and Mail.ru.
- How to choose OKVED industry codes for prospecting in RussiaOKVED is Russia's industry classification. How to pick codes for your ideal customer, main vs additional codes, and common mistakes.
- How to find a Russian company's email addressWhere Russian companies publish emails - website pages, the state register, maps - and how to choose the right address for a business letter.