Privacy Policy

1. General Provisions

This privacy policy has been drawn up in accordance with the local laws of the territory in which the company’s project or actions are being implemented (hereinafter—Privacy Law) and defines the procedure through which personal data shall be processed as well as the means through which G GATE MEDIA (hereinafter—the “Operator”) shall ensure personal data security.

1.1. The Operator considers the observance of human and citizens’ rights and freedoms as its primary objective in the processing of their personal data, including protecting their right to the inviolability of their privacy, as well as personal or family secret.

1.2. This Privacy Policy of the Operator (hereinafter—the “Policy”) applies to all https://ggm-global.com Website visitor data that the Operator may receive.

2. Key Terms Used in the Policy

2.1. Automated personal data processing: the processing of personal data using computer equipment.

2.2. Blocking of personal data: the temporary suspension of personal data processing (except when necessary to clarify personal data).

2.3. Website: the environment of graphic and information materials, as well as computer programs and databases to render them accessible on the Internet, at the network address https://ggm-global.com 

2.4. Personal data information system: the collective sum of personal data contained in databases along with the information technologies and technical means that enable their processing.

2.5. Anonymization of personal data: actions that render it impossible to determine whether personal data belongs to a specific user or other personal data subject without the need for additional information. 

2.6. Personal data processing: any action (operation) or combination of actions (operations) taken with personal data, whether via automation or without using such means, including collecting, recording, systematizing, accumulating, storing, clarifying (updating, modifying), retrieving, using, transmitting (disseminating, providing, issuing access), anonymizing, blocking, deleting, or destroying personal data.

2.7. Operator: the state authority, municipal body, legal entity, or individual that, whether independently or jointly with other persons, organizes or carries out the personal data processing, as well as setting the personal data processing objectives, the components of personal data subject to processing, and the actions (operations) taken with respect to personal data.

2.8. Personal data: any information either directly or indirectly related to a particular or identifiable User of the Website https://ggm-global.com. 

2.9. Personal information authorized by the personal data subject to be disseminated: personal data to which access has been granted to an unlimited number of persons by way of consented provision of personal data authorized by the personal data subject to disseminate it in the fashion envisaged by Privacy Law (hereinafter—”Personal data authorized for dissemination”).

2.10. User: any visitor of the website https://ggm-global.com 

2.11. Provision of personal data: actions aimed at disclosing personal data to a specific person or specific group of persons.

2.12. Personal data dissemination: any actions taken for the purposes of disclosing personal data to a specific group of persons (transmission of personal data) or for familiarization with a specific group of persons’ personal data, including the divulging of personal data on mass media platforms, publishing on television information networks, or the provision of access to personal data via any other method.

2.13. Cross-border personal data transfer: the transfer of personal data onto the territory of a foreign state, to a foreign government authority, to a foreign national, or to a foreign legal entity.

2.14. Destruction of personal data: any actions which result in personal data becoming irrevocably destroyed, with no possibility of subsequently restoring those personal data contents in a personal data information system and/or the physical medium on which the personal data is stored is destroyed.

3. Key Rights and Obligations of the Operator

3.1. The Operator has the right to:

— receive accurate information and/or documents containing personal data from the personal data subject;

— continue processing personal data without the personal data subject’s consent, in the event that the personal data subject revokes their consent to the processing of their personal data and sends a message demanding that the processing of personal data cease, if the grounds exist to do so under Privacy Law; 

— independently establish the contents and list of measures necessary and sufficient to ensure fulfillment of its obligations as envisaged by Privacy Law and taken in accordance with the normative acts thereof, unless otherwise envisaged by Privacy Law or other federal laws.

3.2. The Operator obliges to:

— provide to the personal data subject information related to the processing of their personal data upon their request;

— organize personal data processing in the fashion established by the current laws of the Russian Federation;

— respond to messages and requests from the personal data subjects as well as their legal representatives in accordance with Privacy Law;

— inform the privacy authority upon their request within 10 days following the date that said request is received;

— publish or otherwise provide unlimited access to this Privacy Policy;

— take legal, organizational, and technical steps to protect personal data from illegal or accidental access to them, destruction, modification, blocking, copying, provision, or dissemination of personal data as well as other illegal actions with respect to personal data;

— cease the transfer (dissemination, provision, or issue of access) to personal data, cease processing thereof, and destroy personal data in the fashion and in the cases envisaged by Privacy Law;

— fulfill other obligations envisaged by Privacy Law.

4.  Key Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

— be informed on the processing of their personal data, with the exception of cases envisaged by federal law. The Operator shall provide information to the personal data subject in an accessible form, and it must not contain personal data belonging to other personal data subjects, except in cases where there is a legal basis for disclosing said personal information. The list of information and the fashion in which it shall be obtained is envisaged in Privacy Law;

— request that the Operator clarify what personal data it is storing, that it be blocked, or to destroy it in the case that the personal data are incomplete, outdated, inaccurate, have been obtained through illegal means, or are unnecessary for the stated processing goal, as well as taking measures envisaged by law to defend their rights;

— stipulate a requirement for preliminary consent in the processing of their personal data for the purposes of marketing goods, works, and services;

— withdraw consent to the processing of personal information, along with sending a message to cease processing their personal data;

— file a grievance with the Privacy Authority or a lawsuit regarding illegal Operator actions or inaction in the handling of their personal data in court;

— exercise other rights envisaged by the laws of the Russian Federation.

4.2. Personal data subjects oblige to:

— provide accurate data to the Operator;

— inform the Operator in the event of changes (updates, modifications) to their personal information.

4.3. Persons who transfer inaccurate information to the Operator or information on another personal data subject without said subject’s consent thereto shall be liable according to the laws of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data processing shall be carried out on a lawful and fair basis.

5.2. The processing of personal information shall only be completed to the extent necessary for specific pre-defined, legal purposes. The processing of personal data that is incompatible with the purposes of their collection is not permitted. 

5.3. The merging of databases containing personal data whose processing is carried out for mutually incompatible purposes is not permitted.

5.4. Only personal data relevant to the purposes of their processing shall be subject to processing. 

5.5. The content and scope of processed personal data shall correspond to the stated processing purposes. The processed personal data shall not exceed the stated purposes of their processing.

5.6. Throughout the processing of personal data, it is ensured that they are accurate, sufficient, and in some cases, up-to-date with respect to the purposes for which the personal data are being processed. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows the personal data subject to be identified for no longer than the purposes of the personal data processing require, unless the time period for which the personal data’s storage is envisaged by law or agreement, of which the personal data subject is a party as a beneficiary or a guarantor. Processed personal data is destroyed or anonymized at the moment that the processing purposes are fulfilled or in the case that those purposes no longer need to be fulfilled, unless otherwise envisaged by federal law.

6. Personal Data Processing Purposes

Processing purpose	providing the User access to the services, information, and/or materials contained on the Website
Personal data	last name, first name, patronymic, email address, anonymized visitor data (including cookie files) via Internet statistics services (Yandex Metrika, etc.).
Legal grounds	Federal law 149-FZ “On information, information technologies, and information protection,” passed on 7/27/2006
Forms of personal data processing	Collection, recording, systemization, accumulation, storage, destruction, and anonymization of personal data

7. Personal Data Processing Terms

7.1. Personal data processing shall be carried out with the consent of the personal data subject to process their personal data.

7.2. Personal data processing is necessary to satisfy the purposes envisaged in an international agreement of the Russian Federation or in the law for carrying out the functions, powers, and obligations that Russian Federation legislation has imposed on it. 

7.3. Personal data processing is necessary for the administration of justice, to execute judicial acts, and to enforce the acts of other government bodies or officials, subject to enforcement in accordance with the law of the Russian Federation on enforcement proceedings.

7.4. Personal data processing is necessary to execute agreements, a party to which the personal data subject is either the beneficiary or the guarantor, as well as to conclude an agreement by initiative of the personal data subject or an agreement under which the personal data subject will be a guarantor or beneficiary.

7.5. Personal data processing is necessary to exercise the rights and legal interests of third parties or to satisfy publicly significant purposes under the condition that the rights and freedoms of a personal data subject will not be breached in the process.

7.6. Personal data is processed, to which the personal data subject provides access for a limited circle of persons or it is provided upon their request (hereinafter—”Publicly available personal data”).

7.7. Personal data is processed subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collecting, Storing, Transferring, and Otherwise Processing Personal Data

The security of personal data processed by the Operator is ensured by way of implementing the legal, organizational, and technical measures necessary to fully carry out the current legal data privacy requirements. 

8.1. The Operator ensures the security of personal data and takes every available measure to ensure that no unauthorized persons can access personal data.

8.2. The User’s personal data will never under any circumstances be transferred to third parties, except for cases related to carrying out current laws or in a case where the personal data subject has provided the Operator their consent to transfer them to a third party as part of carrying out their obligations under a commercial contract.

8.3. In the event that inaccuracies are discovered within a subject’s personal data, the User can update them independently, by way of sending a notification to the Operator’s email address contact.media@gg.group with the subject “Personal Data Update”.

8.4. The period for processing personal data is defined as the extent to which is necessary to satisfy the purposes for which the personal data were collected, unless otherwise envisaged by agreement or current laws.

The User can revoke their consent to the processing of their personal data at any time by sending a written email to the Operator to their email address contact.media@gg.group with the subject “Revocation of Consent to Data Processing”. 

8.5. All information gathered by third-party services, including payment systems, communication media, and other service providers, is stored and processed by the indicated persons (Operators) in accordance with their User Agreement and Confidentiality Policy. The operator bears no responsibility for the actions of third parties, including those indicated in this service providers section.

8.6. Prohibitions that the personal data subject sets up on the transfer (beyond access provision) as well as the processing or the conditions for processing (beyond issuing access) their personal data authorized for dissemination are invalid in cases that personal data is processed in government, public, and other interests set out in the laws of the Russian Federation.

8.7. Throughout the processing of personal data, the Operator ensures that the personal data is kept confidential.

8.8. The Operator stores the personal data in a fashion that allows the personal data subject to be identified for no longer than is required for personal data processing purposes, unless the personal data storage period is established by federal law or agreement, to which the personal data subject is a party as a beneficiary or a guarantor.

8.9. Grounds for the cessation of personal data processing can be satisfaction of the data processing purposes, expiration of the period for which the personal data subject provided consent, the personal data subject’s revocation of their consent, or a demand to cease processing personal data as well as the discovery that personal data has been unlawfully processed.

9. List of Actions the Operator Performs with Obtained Personal Data

9.1. The Operator engages in the collection, recording, systemization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access granting), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator performs automated processing of personal data, involving the receipt and/or transmission of the obtained information via information and telecommunication networks or otherwise. 

10. Cross-Border Personal Data Transfer

10.1. Prior to commencing cross-border personal data transfer, the Operator is required to notify the Privacy Authority of its intention to carry out said cross-border transfer (this notification is to be submitted separately from the notification of its intent to process personal data).

10.2. Prior to submitting the aforementioned notification, the Operator is required to obtain the relevant information from the authorities of the foreign state, foreign nationals, and foreign legal entities, to whom the cross-border personal data transfer is planned to be made.

11. Personal Data Confidentiality

The Operator or other persons who have gained access to personal data oblige not to disclose them to third parties or disseminate the personal data without the personal data subject’s consent unless otherwise envisaged by federal law.

12. Concluding Provisions

12.1. The User may obtain an explanation on any issues they are interested in pertaining to the processing of their personal data by emailing the Operator at its email address contact.media@gg.group.

12.2. Any changes to the Operator’s Privacy Policy will be reflected in this document. The Policy remains current until the point at which it is replaced by a new version.

12.3. The current version of the Policy is publicly available on the Internet at  https://ggate.world/privacy-policy/