Privacy Policy
1. General Provisions
1.1. This document establishes the Privacy Policy for the Processing of Personal Data (hereinafter referred to as the Policy) of Unigreen Energy LLC (hereinafter referred to as the Operator) with respect to personal data processed by the Operator on the Website, and sets forth the rules for the personal data processing and the implemented measures for ensuring its security.
1.2. Personal data is classified as confidential information and is protected against unauthorized access, including accidental.
1.3. This Policy is a publicly available document on the Website.
1.4. This Policy applies solely to the Website. The Operator does not control and is not responsible for third-party websites that the User may access via links available on the Website.
2. Terms and Definitions
Automated processing of personal data means processing of personal data using computer hardware.
Blocking of personal data means temporary cessation of personal data processing (except where processing is necessary to clarify personal data).
Personal data information system means a collection of personal data contained in databases, and information technologies and technical means that enable their processing.
Anonymization of personal data means actions that make it impossible to determine the ownership of personal data to a specific data subject without using additional information.
Processing of personal data means any action (operation) or set of actions (operations) performed with or without the use of automation tools involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
Operator means a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and/or performs the processing of personal data, as well as determines the purposes of personal data processing, the categories of personal data to be processed, and the actions (operations) performed with personal data.
Personal data means any information relating directly or indirectly to an identified or identifiable individual (data subject).
Provision of personal data means the disclosure of personal data to a specific person or a specific group of persons
Distribution of personal data means the disclosure of personal data to the public.
Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign government body, individual, or legal entity.
Destruction of personal data means actions that make it impossible to restore the content of personal data in the personal data information system and/or result in the destruction of the tangible (physical) media containing such data.
Website means the Operator's website(s) located on the Internet, whose terms of use refer to this Policy, as well as any development thereof and/or addition of new features, including subdomains of the Website whose terms of use refer to this Policy, application programming interfaces (APIs) used to govern the legal relationship between the Operator and personal data subjects, and the Operator's pages (profiles) on social networks.
3. Principles and Conditions of Personal Data Processing
3.1. Principles of personal data processing
The Operator processes personal data based on the following principles:
Legal grounds for processing personal data;
Limiting the processing of personal data to achieving specific, pre-defined, and legitimate purposes;
Prohibiting the processing of personal data that is incompatible with the purposes for which the data were collected;
Prohibiting the merging of databases containing personal data that are processed for incompatible purposes;
Processing only personal data that meet the purposes of their processing;
Ensuring the content and volume of processed personal data are consistent with the stated purposes of processing;
Preventing the processing of personal data that is excessive for the stated purposes of processing;
Ensuring the accuracy, adequacy and relevance of personal data in relation to the purposes of processing;
Destruction or depersonalization of personal data upon achievement of the purposes of their processing or in the event of losing the need to achieve these purposes, unless the Operator is able to remedy the violations committed, unless otherwise provided by the legislation of the Russian Federation.
3.2. Conditions for personal data processing
The Operator processes personal data if at least one of the following conditions is met:
The processing is carried out with the consent of the personal data subject;
The processing is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, to carry out and perform the functions, powers and duties assigned to the Operator by the legislation of the Russian Federation;
The processing is necessary for the administration of justice, execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceeding;
The processing is necessary for the performance of a contract to which the personal data subject is a party or beneficiary or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor;
The processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the personal data subject are not violated;
The processing concerns personal data authorized for distribution by the subject;
The processing concerns personal data subject to publication or mandatory disclosure under the legislation of the Russian Federation.
3.3. Confidentiality of personal data
The Operator and other persons who have gained access to personal data shall not disclose it to third parties or distribute it without the consent of the personal data subject, unless otherwise provided by the legislation of the Russian Federation.
4. Rights and Obligations
4.1. The personal data subject has the right to:
Receive information concerning the processing of their personal data in accordance with the procedure, form, and time limits prescribed by the legislation of the Russian Federation;
Demand that their personal data be rectified, blocked, or destroyed if it is incomplete, outdated, or inaccurate; if it was obtained unlawfully; if it is no longer necessary for the stated purpose of processing; or if it is being used for purposes other than those for which the data subject previously gave their consent;
Protect their rights, if they believe that the Operator is violating them;
Withdraw their consent to the processing of personal data;
Exercise other rights provided by the legislation of the Russian Federation.
4.2. The Operator has the right to:
Process personal data of the personal data subject in accordance with the stated purpose;
Require the personal data subject to provide accurate personal data necessary for the performance of the contract, identification of the personal data subject, as well as in other cases provided for by the legislation of the Russian Federation;
Restrict the data subject's access to their personal data in cases where granting such access would violate the rights and legitimate interests of third parties, as well as in other instances provided for by the legislation of the Russian Federation;
Process personal data subject to publication or mandatory disclosure in accordance with the legislation of the Russian Federation;
Entrust the processing of personal data to another person with the consent of the personal data subject;
Exercise other rights provided by the legislation of the Russian Federation.
4.3. The Operator is obliged to:
Organize the processing of personal data in accordance with the requirements of the legislation of the Russian Federation;
Ensure the protection of personal data processed by the Operator from their unlawful use or loss;
Maintain the confidentiality of personal data;
Respond promptly and in accordance with the requirements of the legislation of the Russian Federation to appeals and requests from personal data subjects and their legal representatives;
Provide the Federal Service for Supervision of Communications, Information Technology, and Mass Media (Roskomnadzor) with the necessary information upon its request, within the time limits prescribed by the legislation of the Russian Federation;
Eliminate violations of the legislation of the Russian Federation committed during the processing of personal data;
Clarify, block and destroy personal data in cases provided for by the legislation of the Russian Federation;
Fulfill other requirements established by the legislation of the Russian Federation.
5. Purposes of Personal Data Processing
5.1. Information interaction with the personal data subject (Website users)
Purpose of personal data processing
Responding to inquiries received via the Website's feedback forms
This purpose includes handling inquiries from personal data subjects who have contacted the Operator on various matters (including the processing of such inquiries)
Categories of data subjects whose personal data is processed
Subjects making a request, their representatives
Categories of processed personal data
Others
List of processed personal data
Last name, first name, patronymic; phone number; email address; other information contained in the request
Grounds for personal data processing
Legitimate interest. Consent to personal data processing
Actions performed with personal data
Collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, deletion, destruction of personal data, as well as transfer (provision, access)
Methods of personal data processing
Mixed; with transmission via the internal network of the Operator; with transmission via the Internet
Procedure for destruction of personal data
Destruction is carried out within the time limits established by the legislation of the Russian Federation using standard software tools of the personal data information system; paper media are destroyed by shredding.
5.2. Interaction with counterparties
Purpose of personal data processing
Interaction with counterparties who contacted through the Website's feedback forms
This purpose includes pre-contractual activities, conclusion and execution of contracts, contract settlements, business communication, as well as maintaining a list of current and potential counterparties
Categories of data subjects whose personal data is processed
Counterparties; representatives of counterparties; potential counterparties; representatives of potential counterparties
Categories of processed personal data
Others
List of processed personal data
Last name, first name, patronymic; phone number; email address; other information contained in the request
Grounds for personal data processing
Legitimate interest. Contract. Consent to personal data processing
Actions performed with personal data
Collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, deletion, destruction of personal data, as well as transfer (provision, access)
Methods of personal data processing
Mixed; with transmission via the internal network of the Operator; with transmission via the Internet
Procedure for destruction of personal data
Destruction is carried out within the time limits established by the legislation of the Russian Federation using standard software tools of the personal data information system; paper media are destroyed by shredding.
5.3. Candidate (applicant) selection
Purpose of personal data processing
Candidates (applicants) selection to fill vacant positions, including inclusion in the personnel reserve, who contacted through the Website's feedback forms
Categories of data subjects whose personal data is processed
Applicants for filling vacant positions
Categories of processed personal data
Others
List of processed personal data
Last name, first name, patronymic; phone number; email address; other information contained in the request
Grounds for personal data processing
Consent to personal data processing
Actions performed with personal data
Collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, deletion, destruction of personal data, as well as transfer (provision, access)
Methods of personal data processing
Mixed; with transmission via the internal network of the Operator; with transmission via the Internet
Procedure for destruction of personal data
Destruction is carried out within the time limits established by the legislation of the Russian Federation using standard software tools of the personal data information system; paper media are destroyed by shredding.
5.4. Ensuring Website functionality, including providing technical support to users;
Purpose of personal data processing
Ensuring the functioning of the Website
This purpose includes improving Website performance, ensuring the convenience of viewing its pages and protection against spam bots, analyzing Website user behavior to enhance customer experience, conducting digital marketing activities, and performing lead generation and targeting
Categories of data subjects whose personal data is processed
Website Users
Categories of processed personal data
Others
List of processed personal data
Cookies
Grounds for personal data processing
Consent to personal data processing
Actions performed with personal data
Collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, deletion, destruction of personal data, as well as transfer (provision, access)
Methods of personal data processing
Mixed; with transmission via the internal network of the Operator; with transmission via the Internet
Procedure for destruction of personal data
Destruction is carried out within the time limits established by the legislation of the Russian Federation using standard software tools of the personal data information system; paper media are destroyed by shredding.
5.5. Sending advertising mailings
Purpose of personal data processing
Sending marketing communications, including promotional emails
This purpose includes promoting the Operator's goods and services, increasing customer loyalty, providing special offers, and sending marketing communications via email, push notifications, in-app messages, and SMS
Categories of data subjects whose personal data is processed
Counterparties; representatives of counterparties; potential counterparties; representatives of potential counterparties, Website users
Categories of processed personal data
Others
List of processed personal data
Last name, first name, patronymic; phone number; email address; other information contained in the request
Grounds for personal data processing
Consent to personal data processing
Actions performed with personal data
Collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, deletion, destruction of personal data, as well as transfer (provision, access)
Methods of personal data processing
Mixed; with transmission via the internal network of the Operator; with transmission via the Internet
Procedure for destruction of personal data
Destruction is carried out within the time limits established by the legislation of the Russian Federation using standard software tools of the personal data information system; paper media are destroyed by shredding.
5.6. Employee development
Purpose of personal data processing
Employee development
This purpose includes organizing and conducting advanced training programs, professional retraining programs, and any other forms of training aimed at employee development.
Categories of data subjects whose personal data is processed
the Operator's employees; attendees of seminars, webinars, and other staff training and development events;
Categories of processed personal data
Others
List of processed personal data
Last name, first name, patronymic; records of name changes (previous full name); gender; date of birth; place of birth; citizenship; passport details; records of passport changes and details of previously issued identity documents; residential address (actual place of residence); registration address (place of registration); phone number; email address; migration card details; photograph; education details; information on professional training, retraining, and advanced training; profession, qualification, specialization; academic degree and title; training and test results; employment history, including previous places of work (company name, position, tenure/period of employment); foreign language proficiency; employee ID (personnel number); place of work, position, and structural unit/department; information on achievements (awards, merits, etc.).
Grounds for personal data processing
Contract. Consent to personal data processing
Actions performed with personal data
Collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, blocking, deletion, destruction of personal data, as well as transfer (provision, access)
Methods of personal data processing
Mixed; with transmission via the internal network of the Operator; with transmission via the Internet
Procedure for destruction of personal data
Destruction is carried out within the time limits established by the legislation of the Russian Federation using standard software tools of the personal data information system; paper media are destroyed by shredding.
6. Rules for Personal Data Processing
6.1. Personal data collection
Personal data shall be collected directly from the personal data subject themselves. If the provision of personal data and/or obtaining of consent to process personal data by the Operator is mandatory in accordance with the legislation of the Russian Federation, the legal consequences of refusing to provide such data and/or consent to their processing shall be explained to the personal data subject.
Obtaining personal data from other persons is possible only if there are legal grounds. When receiving personal data from third parties, unless such data was obtained under a data processing instruction or the transferring party has obtained the necessary consent, the data subject must be informed accordingly.
When collecting personal data, including via the Internet, the Operator ensures that the recording, systematization, accumulation, storage, clarification (updating, modification), and retrieval of personal data of citizens of the Russian Federation are carried out using databases located on the territory of the Russian Federation.
6.2. Personal data storage
Personal data shall be stored in a form that permits identification of data subjects for no longer than is necessary to achieve the purposes for which they are processed, unless a longer storage period is required by the legislation of the Russian Federation or by a contract to which the data subject is a party.
Personal data shall be stored in a manner that ensures its confidentiality.
Upon achievement of the purposes of processing, or in the event of losing the need to achieve these purposes, personal data shall be transferred for archival storage in accordance with the archiving legislation of the Russian Federation, or shall be destroyed or depersonalized, unless otherwise provided by the legislation of the Russian Federation or a contract to which the data subject is a party.
6.3. Personal data transfer
Personal data shall be transferred to a third party only with the consent of the personal data subject or in cases expressly provided for by the legislation of the Russian Federation
The transfer of personal data to state authorities, local government bodies, security and law enforcement agencies, state institutions and funds, as well as to other authorized bodies, is permitted on the grounds provided for by the legislation of the Russian Federation.
Disclosure of personal data to a third party without the consent of the relevant subject is not permitted, except in cases where this is necessary to protect the life, health or other vital interests of the personal data subject.
Disclosure of personal data to a third party for commercial purposes without the consent of the relevant subject is prohibited. Personal data processing for the purpose of promoting goods, works, services on the market, as well as for the purpose of political agitation, is carried out only subject to the prior consent of the subject.
Cross-border transfer of personal data to the territories of foreign states is not carried out.
6.4. Conditions and procedure for terminating the personal data processing
Once the purpose of the processing is achieved, the processing of such personal data must be terminated, and the personal data must be destroyed within thirty days from the date of achieving the purpose of the personal data processing, unless otherwise provided by the contract to which the personal data subject is a party, beneficiary or guarantor, another agreement between the Operator and the personal data subject, or if the Operator is not entitled to process personal data without the consent of the personal data subject on the grounds provided for by the legislation of the Russian Federation.
Upon the data subject's withdrawal of consent to the processing of their personal data, such processing must be terminated. If the retention of the personal data is no longer required for the processing purposes, the data shall be destroyed within thirty days from the date of receiving the withdrawal, unless a longer retention period is provided for by a contract to which the data subject is a party, beneficiary, or guarantor, by another agreement between the Operator and the data subject, or unless the Operator is entitled to process the data without consent on other grounds provided for by the legislation of the Russian Federation.
In the event of detection of unlawful processing of personal data, the processing of such personal data must be terminated within three working days. If it is impossible to ensure the lawfulness of the processing of personal data, the personal data is subject to destruction within ten working days from the date of detection of the unlawful processing.
If it is impossible to destroy personal data within the period specified in this clause, such personal data must be blocked and subsequently destroyed within a period not exceeding six months, unless a different period is established by the legislation of the Russian Federation.
6.5. The right to access personal data processed by the Operator is held by:
Sole executive body of the Operator;
Operator's employees who need to process personal data in order to perform their official duties;
Other persons in cases where the processing is legally justified under the legislation of the Russian Federation.
6.6. The terms for processing and storing personal data for each purpose specified in Section 5 hereof are established in accordance with the requirements of the current Russian legislation, including the conditions for processing personal data, as well as taking into account the provisions of any contract to which the data subject is a party, beneficiary, or guarantor, and/or the data subject's consent to the processing.
In any case, personal data shall not be processed or stored longer than necessary to achieve the purposes for which they are processed, unless a longer period is required by the legislation of the Russian Federation.
7. Use of Cookies
7.1. The Website uses cookies to ensure its functionality, improve performance and viewing convenience, protect against spam bots, analyze user behavior to enhance customer experience, and carry out digital marketing, lead generation, and targeting.
7.2. Cookies are small text files stored on a user's device when they visit the Website. These files usually contain alphanumeric identifiers that uniquely recognize the user's device, and may also include other technical information.
7.3. Depending on the purpose, the following categories of cookies are used on the Website:
- Strictly necessary (technical) cookies – necessary for the functioning of the Website and enabling its core functions.
- Analytical cookies – used to collect aggregated information about user actions on the Website, including the number of visits, pages viewed, session duration, and other metrics used to analyze how the Website is used and improve its quality.
7.4. For analytics purposes, third-party web analytics services may be used. In this case, certain data collected via cookies is used in accordance with their respective privacy policies.
7.5. Functional and analytical cookies are used only with the user's prior consent. Consent is given by clicking the confirmation button in the pop-up notification upon the first visit to the Website.
7.6. If the user does not consent to the use of functional and/or analytical cookies, these cookies will not be stored on their device. As a result, some features and functions of the Website may be limited or unavailable.
7.7. Users may withdraw their consent to the use of cookies at any time. This can be done by deleting cookies stored on their device or by adjusting their browser settings, including completely disabling cookies.
8. Measures to Ensure Compliance with the Legislation of the Russian Federation
8.1. The Operator is required to take measures necessary and sufficient to ensure compliance with the obligations provided for by the Russian personal data legislation. The Operator independently determines the composition and list of measures it deems necessary and sufficient for this purpose. Such measures, in particular, include:
Appointing a person within the Operator (a legal entity) responsible for organizing the processing of personal data;
Adopting internal documents defining the Operator's policy on personal data processing. These documents specify, for each processing purpose: the categories and list of personal data processed, the categories of data subjects, the methods and terms of processing and storage, and the procedure for destroying personal data once the purposes are achieved or other legal grounds arise. They also include internal regulations establishing procedures to prevent and detect violations of Russian Federation Legislation and to eliminate their consequences. Such documents may not contain provisions restricting the rights of data subjects or impose on the Operator any duties or powers not provided for by the legislation of the Russian Federation;
Applying legal, organizational, and technical measures to ensure the security of personal data in accordance with Article 19 of the Federal Law "On Personal Data";
Conducting internal control and/or audits to verify that the processing of personal data complies with the legislation of the Russian Federation, personal data protection requirements, this Policy, and the Operator's internal documents;
Assessing the potential harm to data subjects in the event of a breach of Russian legislation, and correlating such harm with the measures taken by the Operator to fulfill its statutory obligations;
Training the Operator's employees directly involved in the processing of personal data, and/or acquainting them with the provisions of Russian data protection legislation, including personal data security requirements, the Operator's policy documents, and internal regulations on personal data processing;
Publishing this Policy or otherwise providing unrestricted access to it on the relevant information and telecommunications networks, including on the Operator's Website through which personal data is collected.
8.2. When processing personal data, the Operator implements all necessary legal, organizational, and technical measures to protect personal data against accidental or unlawful access, destruction, alteration, blocking, copying, disclosure, distribution, and other unlawful acts.
To ensure data security, the Operator undertakes the following:
Identifying security threats to personal data processed in information systems;
Applying organizational and technical measures to ensure the security of personal data during their processing in information systems in order to meet the required security levels;
Using information security tools that have been duly certified;
Using certified information security tools with data destruction functionality to destruct personal data;
Assessing the effectiveness of security measures applied to personal data in information systems;
Maintaining records of personal data storage media;
Detecting and responding to incidents of unauthorized access to personal data;
Restoring personal data modified or destroyed as a result of unauthorized access;
Establishing access rules for personal data processed in information systems;
Logging and tracking all actions involving personal data in information systems;
Monitoring the implementation of security measures and the security level of personal data information systems.
9. Responsibility
9.1. The Operator shall bear administrative and civil liability under the legislation of the Russian Federation for any failure to comply with the rules set forth in this Policy.
9.2. Employees of the Operator who are duly authorized to process personal data shall bear material, disciplinary, administrative, civil, and criminal liability under the legislation of the Russian Federation for any violation of the rules provided for by this Policy.
10. Final provisions
10.1. This Policy may be amended or supplemented to reflect changes or additions to the current legislation of the Russian Federation. The Policy may also be updated at any time at the Operator's sole discretion without prior notice to the Website users.
10.2. Any other rights and obligations of the Operator relating to the processing of personal data shall be governed by the legislation of the Russian Federation.
10.3. Amendments to this Policy take effect upon the publication of the revised version of the Policy on the Website.
11. Operator's Details and Contact Information
Full name: Unigreen Energy Limited Liability Company
Short name: Unigreen Energy LLC
INN (Taxpayer Identification Number): 9728011406
KPP (Tax Registration Reason Code): 772801001
OGRN (Primary State Registration Number): 1207700315745
Legal address: 65 Profsoyuznaya str., bldg. 1, floor 14, room XL, off. 7.05, Moscow, 117342