Privacy PolicyKey concepts and purpose
Operator – Greenwich, LLC (Saint-Petersburg, Barochnaya st., 12B, office 421, postal code 197136)
Personal data subject (Subject) – Site visitor;
Site –
https://greenwichtech.info/ set of programs for electronic computers and other information contained in an information system, access to which is provided through the information and telecommunications network "Internet" (hereinafter referred to as the "Internet") by domain names and/or by network addresses that allow identification of sites on the "Internet";
Personal data – any information relating to a directly or indirectly identified or identifiable individual (personal data subject); Personal data processing – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, updating (renewal, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
Automated personal data processing – the processing of personal data using computer equipment.
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" and defines the basic concepts, rights, and obligations of the Personal Data Subject and the Operator, the procedure for processing personal data, and measures to ensure the security of personal data.
Purposes of collecting personal data
The operator collects personal data:
- to display the content of the Site to the Visitor,
- to register the Subject's requests to the Operator,
- to generate and send a response to the Subject’s request,
- to prepare and send a commercial offer at the Subject's request,
- to conclude and execute agreements with the Subject.
Legal grounds for processing PD
Federal Law No. 152-FZ of July 27, 2006, "On Personal Data";
Federal Law No. 149-FZ of July 27, 2006, "On Information, Information Technologies, and Information Protection";
Civil Code of the Russian Federation;
Federal laws and other regulatory legal acts in the field of personal data protection;
Consent of the Subject to the processing of their personal data.
Scope and categories of personal data
The Operator processes the cookies necessary to provide access to the Site, without the processing of which the site will not be displayed correctly. Each visitor to the Site consents to the processing of the necessary cookies for the purpose of displaying the content of the Site through implied actions — if they stay on the Site page.
The Operator processes statistical cookies to collect statistical information about visitors to the Site. Each visitor to the Site consents to the processing of statistical cookies for the purpose of displaying the content of the Site through implied actions — by checking the box in the cookie settings.
The Operator processes the Site Visitor's email address to receive questions and requests for commercial offers from Site Visitors, as well as to send responses to Site Visitors' questions and requests. The Site Visitor consents to the processing of their email address through implied actions — by sending a message to the Operator's email and/or postal address specified on the website.
The Operator processes other information that the Site Visitor voluntarily indicates in their request to the Operator. The Operator processes other information voluntarily provided by the Site Visitor to generate a response to their request, including for the purposes of cost calculations and forming a commercial offer. The Site Visitor agrees to the processing of other information specified in a request to the Operator by providing an email address through implied actions — sending a message to the Operator's email and/or postal address specified on the website. In the event of an agreement being concluded with the Operator, further processing of the personal data of the Subject or their representatives is to be carried out on the basis of the concluded agreement.
The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, sex, or biometric personal data, except in cases stipulated by Russian legislation.
Procedure and conditions for processing personal data
The Operator processes Personal Data with the consent of the Subject (exceptions to this rule are directly stipulated in the Law "On Personal Data").
The Operator uses automated and mixed methods for processing the Personal Data of the Site Visitors.
The Operator stores personal data no longer than required for the purposes of processing personal data, unless a different period is established by law or contract.
Only the Operator's employees whose job responsibilities include processing personal data are allowed to process personal data. The Operator does not allow the disclosure of personal data of Subjects to third parties without the Subject's consent (except in cases of disclosure of information to authorized bodies; exceptions are expressly specified in the Law “On Personal Data”).
Grounds for termination of Personal Data processing:
an instance of unlawful processing has been identified;
the purpose of their processing has been achieved;
the consent period has expired or been revoked by the personal data Subject for the processing of the specified data (if processing is only possible with the consent of the Subject).
Rights and obligations of the Operator and Subject
The Operator is obliged to take the necessary legal, organizational, and technical measures or ensure their adoption to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data.
The Operator has the right to independently determine the composition and list of measures necessary and sufficient to fulfill the obligations stipulated by the Law "On Personal Data". The list of these measures is contained in Articles 18.1 and 19 of the Law “On Personal Data”.
The Operator is obliged to notify the authorized agency for the protection of the rights of personal data subjects (the Federal Service for Supervision of Communications, Information Technology, and Mass Media (Roskomnadzor)) about any cases of compromise (instances of unlawful or accidental transfer (provision, distribution, access) of personal data, resulting in a violation of the rights of personal data subjects) of personal data.
The Operator has the right to entrust the processing of Personal Data to a third party is the consent of the Subject has been given.
The personal data Subject has the right to contact the Operator with a request to check their personal data, block it, or destroy it, in the event that the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing.
The request must contain:
- the number of the main document certifying the identity of the personal data Subject or their representative (information about the date of issue of the specified document and the authority that issued it);
- information confirming the participation of the personal data Subject in relations with the Operator or information otherwise confirming the instance of processing of personal data by the Operator;
- the signature of the personal data Subject or their representative (if the request is sent electronically, the request must be signed with a qualified electronic signature).
The Subject has the right to send a request to the Operator to check their personal data. The Operator's response period is 10 business days, a period which may be extended by 5 business days, about which the Operator will notify the personal data Subject.
The Subject has the right to send a request to the Operator to stop processing their personal data. The Operator will stop processing the Subject's personal data within 10 business days. The specified period may be extended by 5 business days, about which the Operator will notify the Subject.
The Subject has the right to withdraw their consent to the processing of their personal data. The Operator will stop processing and destroy the personal data within 30 days of the date the consent is withdrawn.
The Operator has the right to continue processing personal data even after receiving a request to stop processing or a withdrawal of consent by the Subject for the processing of personal data, in cases specified in clauses 2-11 of part 1 of Article 6, part 2 of Article 10, and part 2 of Article 11, of the law "On Personal Data", including for the fulfillment of requests and requirements of government agencies, for the protection of the life, health, and rights of the subject, and for the administration of justice.
If the Subject believes that their rights have been violated, they have the right to appeal the actions or inaction of the Operator to the authorized agency (Roskomnadzor) or through a court.