152-FZ and an escort agency: what the client should know
Why 152-FZ at all
Clients of professional services sign "consent for personal-data processing" routinely — at couriers, banks, parking. At an escort agency the consent is the same but the frame is stricter. We process two categories of subjects in parallel (clients + companions), both highly sensitive. 152-FZ is the framework that holds our privacy practice together.
What we collect from a client
Mandatory minimum:
- Name (a pseudonym is acceptable; a reception-grade name for contact)
- Contact channel (Telegram handle, WhatsApp number, phone)
- Engagement location (venue name)
On client request (extended scenarios only):
- Full legal name for an NDA
- Delivery address if the client wants the companion to come to a home / office
- Partner context (if the client requests a photographic screening for the brief)
We do NOT collect:
- Passport data
- Tax / banking information
- Family, employer, or colleague contacts
- Call history, medical certificates
Where data lives, who has access
Database lives on a PostgreSQL server under Russian jurisdiction (Moscow data center, no foreign cloud infra). Access:
- Two coordinators on shift (see name + channel + current-booking venue)
- Editor-in-chief / admin (sees historical requests but not partner names)
- Legal — only on a regulatory inquiry
The companion never sees historical client data, only the brief for the current engagement. The coordinator deletes the brief from her work chat after the meeting.
Auto-deletion schedule
| Data | Retention | |---|---| | Engagement brief | 7 days post-meeting | | Client name + channel | 12 months since last booking | | NDA documents | per the NDA term | | Partner photos (if shared) | 24 hours post-meeting | | Transaction records | 6 years (Russian accounting requirement) |
Auto-deletion runs by cron. Deletion logs kept 90 days for audit.
Early deletion
Write the coordinator: "Please delete my data per 152-FZ". Within 24 hours we:
- Remove name + channel from the active database
- Erase any stored briefs
- Confirm via the same channel
Transaction records can't be removed early — law requires 6-year retention.
Mandatory before the first booking
The coordinator sends a link to our Privacy Policy. On explicit consent ("agree" or equivalent) the request opens. Without explicit consent the request doesn't open. Not a dark pattern, the letter of 152-FZ.
Open questions
Escort MSK Legal answers written inquiries within 5 business days. Address: /en/kontakty. If our answer is unsatisfactory, you have the right to escalate to Roskomnadzor — we will share the inquiry template.