Privacy Policy

This Personal Data Processing and Protection Policy (the Policy) is adopted and in effect to all information about the User that may be obtained during the use of the site http://greenfingroup.com (the Site), its programs and products.

1. Key terms and definitions

“Personal data” is any information that is related directly or indirectly to a specific or identifiable individual (subject of personal data).

“Personal data processing” is performing any actions or sets of actions (operations) with respect to your personal data including the following: collect, record, systematization, gather, store, update, alter, extract, use, transfer (provide, access), depersonalization, block, delete, destroy with and without the use of personal data automated processing systems.

“Site administration” – authorized employees for the management of the site who organize and (or) carry out the processing of personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.    

“Confidentiality of personal data” is a mandatory requirement for the Administration or any other person who has legally obtained access to personal data to prevent their dissemination without the consent of the subject of personal data or the presence of other legal grounds.

“Website” is a collection of graphic and text information materials, as well as computer programs and databases that ensure their availability on the Internet at a unique address http://greenfingroup.com

“Site User” (the User) – a person who has access to the Site via the Internet and uses the information, materials and products of the Site.

“Cookies” – a small piece of data sent by a web server and stored on the User’s computer, which the web client or web browser sends to the web server each time in an HTTP request when trying to open a page of the corresponding site.

“IP address” is the unique network address of the node in the computer network through which the User accesses the Site.

2. General

We may collect and use the personal data you provide to us when:

• you access the Website from any device or when communicating with us in any form in compliance with this Policy. By using the Website and providing your personal data to us, you give your consent to have your personal data processed in compliance with this Policy.
• you get in touch with us with a question, complaint, comment or feedback (such as name, contact details and contents of the communication).  In these cases, the subject of personal data is in control of the personal data shared with us and we will only use the data for the purpose of responding to the communication and handling the matter as appropriate. The personal data referred above may include name, employer name, contact title, phone, email and other business contact details.
• you apply online for a job at the Company via Website.

In case of disagreement with the terms of the Policy, we recommend that the User stop using the Site.

The Administration does not verify the accuracy of the personal data provided by the User.

3. The Principles of processing of personal data

• We process personal data lawfully and fairly.
• Processing involves only the personal data which meet the intended purposes of the processing thereof.
• The contents and scope of processed personal data correspond to the declared purposes of processing. Processed personal data is not excessive in respect of the declared purposes of processing thereof.
• The term of processing of personal data is limited within the scope of specified, preset and lawful purposes.
• We take all necessary measures for providing security of processing personal data.  
• We respect lawful rights of personal data subjects and ensure their  protection in the processing of personal data.

4. The types of data we collect

We may collect the following types of data:

• the personal data you provide to us when filling out information fields at the Website, including filling out the contact form and subscribing to news mailouts (name, employer name, contact title, phone, email and other business contact details)

• the personal data and other information contained in the messages you send to us

• data that is automatically transmitted when you visit the pages (IP address, information from cookies, browser information, access time, referrer (address of the previous page)

By filling out the appropriate forms and / or sending us your personal data, the User agrees to this Policy.

5.Purposes of personal data processing

We may process your personal data for purposes it has been provided for only, including the following:

• providing you with information about the Company, our services and events
• answering  to your requests and responding to requests for additional information
• organizing your participation in our events and surveys
• sending you our news casts with your permission
• distributing of the requested reference materials
• submitting  a curriculum vitae
• discharging legal, regulatory and professional obligations imposed on the Company in compliance with the Russian law. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.
• conducting client acceptance procedures
• providing or receiving professional services
• developing our businesses and services
• making personal data available to  our employees for performing services and for offering new services
• identifying clients with similar needs
• performing analytics such as on market trends, relationships maps or sales opportunities

The term of processing of personal data is unlimited. The User can withdraw his consent to the processing of personal data at any time by sending us a notification by e-mail to the following email address: info@greenfingroup.com marked “Withdrawal of consent to the processing of personal data”.

The User can always opt out of receiving informational messages by sending us an email to the email address info@greenfingroup.com marked “Opt-out of notifications and news”.

6. Your rights

Protecting your personal data rights and liberties is pivotal to the way we do business.

To ensure your rights and liberties are protected, upon your request, we will:

• confirm whether we process your personal data and will allow you to look through it within 30 days from the receipt of your request
• inform you on the source and contents of your personal data that we process
• inform you on the legal basis, purposes, terms and means of processing your personal data
• introduce the necessary changes to your personal data if you confirm it is incomplete, inaccurate or outdated within 7 business days from the date of the receipt of such confirmation and notify you on the changes made
• notify you on the cross-border transfer of your personal data made or planned
• notify you on the name and location of the organisations, which have access to your personal data and to which your personal data may be disclosed upon your consent
• inform you about the company name or full name of entities/individuals charged with processing your personal data
• notify you on the exercise of your rights during our processing of your personal data
• exclude you from our news mailing list
• stop processing your personal data within 30 days from the date of the receipt of withdrawal of your consent provided there are no other legal basis for personal data processing stipulated by the Russian law
• stop processing your personal data if unlawful processing on our side is confirmed and notify you on remedial action taken
• destroy your personal data if unlawful receipt or unintended use thereof is confirmed within 7 business days from the date of the receipt of such confirmation and notify you on remedial action taken
• answer any questions related to your personal data we process

7. Personal data security

To ensure the security of your personal data during processing, we take all necessary and sufficient legal, organizational and technical measures to protect personal data from unauthorised or accidental access, destruction, alteration, blocking, copying, disclosure, or distribution, as well as against all other unlawful actions with respect to personal data.

For ensuring the adequate protection of your personal data, we assess the potential damage that could be inflicted on you if your personal data were compromised, and identify relevant threats to your personal data security during processing in personal data information systems.

The Company has adopted internal regulations on the personal data security. The Company’s employees who have access to personal data are familiar with this Policy and internal regulations on personal data security.

8. Additional conditions

The Policy is available on the page at: http://greenfingroup.com

The Administration has the right to make changes to the Policy without the consent of the Users.

The new Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new version of the Policy. If you have any suggestions or questions about this Policy, please contact us at: info@greenfingroup.com