Privacy Policy

Personal Data

Processing Policy

1. General Provisions
This Personal Data Processing Policy has been developed in accordance with the requirements of the Federal Law “On Personal Data” No. 152-ФЗ dd. July 27, 2006, and determines the procedure for processing personal data and measures to secure the personal data of GRIDNINE SYSTEMS LLC (hereinafter referred to as the “Operator”).
1.     The main goal and operating conditions for the Operator’s business activity is the observance of rights and freedoms of a person and a citizen in the processing of their personal data, to include protection of their rights to privacy, personal and family secrets.
2.     This Operator's Personal Data Processing Policy (hereinafter referred to as the “Policy”) is applied to all information about the visitors the Operator becomes aware of from its website
2. Basic Policy Notions
1.     Automated personal data processing is the processing of personal data with the use of computer technologies;
2.     Personal data blocking is temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data);
3.     Website is a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at;
4.     Personal data information system is a set of personal data contained in databases, and information technologies and technical means that ensure their processing;
5.     Personal data depersonalization are actions, as a result of which, it is impossible to determine the ownership of personal data by a specific User or other subject of personal data without the use of additional information;
6.     Personal data processing is any action (operation) or a set of actions (operations) performed with personal data using automation tools or without them, to include collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, accessing), depersonalization, blocking, deletion and destruction thereof;
7.     Operator is a state, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing thereof, the composition of personal data to be processed, and actions (operations) to be committed with personal data;
8.     Personal data is any information directly or indirectly relating to a specific or identifiable User of the website;
9.     User is any visitor to the website;
10. Provision of personal data are actions aimed at disclosing personal data to a certain person or a group of persons;
11. Distribution of personal data are any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or becoming aware of such personal data by an unlimited number of persons, to include their disclosure in the media, posting in information and telecommunication networks or otherwise providing access thereto;
12. Cross-border transfer of personal data is transfer of personal data to the territory of a foreign state, the foreign state authority, individual or legal entity;
13. Personal data destruction are any actions as a result of which personal data are destroyed irrevocably with no possibility to restore the content thereof in the related information systems and (or) as a result of which physical media such personal data are store on are destroyed.
3. User’s Personal Data the Operator May Process
1.     Name, surname, patronymic;
2.     E-mail address;
3.     Phone numbers;
4.     Photos;
5.     The site also collects and processes anonymous data about visitors (to include cookies) using Internet statistics services (Yandex Metrica, Google Analytics etc.);
6.     Hereinafter, the aforestated data are combined by one notion – Personal data.
4. Personal Data Processing Targets
1.     The main target of processing the User's personal data is to inform the latter by sending e-mails.
2.     The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive notifications by sending a “Waiver of Notice” to the Operator’s e-mail address;
3.     The Users’ depersonalized data collected using Internet statistics services are used to collect information about the Users’ actions on the website, and improve the quality and content thereof.
5. Personal Data Processing Legal Basis
1.     The Operator processes the User's personal data only if they are filled out and/or sent by the User independently through special forms available at By filling out the relevant forms and/or sending personal data to the Operator, the User expresses its consent to this Policy.
2.     The Operator processes depersonalized User’s data if it is allowed in the latter’s browser settings (saving cookies and JavaScript technology is enabled).
6. Personal Data Collection, Storage, Transfer Procedure and Other Forms of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to fully meet the requirements of applicable legislation in the field of personal data protection.
1.     The Operator ensures the safety of personal data and takes all possible measures to exclude access of unauthorized persons thereto;
2.     The User's personal data will never, and in no event shall be transferred to third parties, unless in cases related to the implementation of applicable law;
3.     Should any inaccuracies in personal data be found, the User can update thereof independently by sending a “Personal data update” notification to the Operator's e-mail address;
4.     The term for processing personal data is unlimited. The User may at any time withdraw its consent to the processing of personal data by sending a “Personal data processing waiver” notification to the Operator's email address
7. Cross-Border Transfer of Personal Data
1.     Prior to performing cross-border transfer of personal data, the Operator is obliged to make sure that the foreign state, such personal data are supposed to be transferred to, provides reliable protection of the rights of subjects of personal data;
2.     Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements is possible only subject to the written consent of the subject of personal data to such transfer and/or execution of an agreement, the subject of personal data is a party to.
8. Final Provisions
1.     The User may receive any clarifications on issues related to the processing of its personal data by contacting the Operator via e-mail;
2.     This document will reflect any changes in the Policy made by the Operator. The policy is valid indefinitely until it is replaced by a new version;
3.     The latest version of the Policy is freely available at