Martin Grey


1. General Provisions

1.1. This Policy with regard to personal data processing (hereinafter referred to as “The Policy”) drafted in accordance with the paragraph 2 of Article 18.1 of the Federal Law "On Personal Data" No. 152-FZ of July 27, 2006, as well as other normative legal acts of the Russian Federation in the field of protection and processing of personal data. The Policy covers all personal data (hereinafter “the data”), which can be obtained from the internet user (hereinafter referred to as “The User") by the Company (hereinafter “The Company”) during his use of the website: The Company compiles information about the users at the minimum level, including name and e-mail, which corresponds to the requirements of the GDPR.

1.2. The Company ensures protection of the processed personal data from unauthorized access and disclosure, misuse or loss in compliance with the requirements of the Federal Law "On Personal Data" No. 152-FZ of July 27, 2006.

1.3. The Company shall be entitled to make amendments to this Policy. When such amendments are made the date of the last update is to be indicated in the heading of the Policy. New edition of the Policy shall come into effect from the moment it is posted on the site, unless otherwise provided for in the new edition of the Policy.

1.4. The personal data subject shall be independently familiarized with the present on the website edition of The Policy, and refuse using the website unless the conditions are accepted.

1.5. The website may contain links to other websites. The company shall not be responsible for content, quality and security policy of these websites. This privacy statement applies only to the information provided directly on the website.

2. Terms and Acronyms

Personal data is any data, relating to a directly or indirectly determined or determinable individual (subject of personal data).

Personal data processing is any action (transaction) or set of actions (transactions), carried out using automation tools or without using such tools with personal data, including compilation, recording, systematization, accumulation, possession, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

Automated personal data processing is processing of personal data by means of computer technology.

Personal data made publicly accessible by the subject of personal data is personal data with access to an unlimited number of individuals which was provided by the subject of personal data or upon his request.

Personal data blocking is a temporary suspension of personal data processing (unless the processing is necessary to clarify personal data).

Personal data destruction is actions which make restoration of personal data content in the personal data information system impossible and (or) as a result of which material carriers of personal data are destroyed.

The Company is an organization that independently or jointly with other individuals organizes the processing of personal data, as well as defines the goals of personal data processing, actions (transactions) performed with personal data. The Company is Martin Gray LLC, a legal entity incorporated under the laws of the United States of America and registered at 16192 Coastal Highway, Lewes, Delaware, 19958.

Website is a set of documents of an organization in a computer network united under one address (domain name or IP address).

3. Personal data processing

3.1. Personal data obtaining

3.1.1. The subject enters all personal data independently through a special form on the website.

3.1.2. Personal data in the context of this policy refers to data about the name and e-mail that is received by the company from the subject through the form on the website, processed and stored by the company for the purposes specified in clause 3.2.2. of this policy, for 25 years or until the revocation of consent to the processing of personal data.

3.2. Personal data processing.

3.2.1. The processing of personal data requires the consent of the subject of personal data to the processing of his personal data;

3.2.2. Purposes of personal data processing:
– to contact the user to complete the feedback form on the website, including sending notifications, requests and information regarding the use of the website;
- to conduct surveys of customer opinions, as well as to send advertising and other mailings with information about the Company's services;
- to depersonalize personal data in order to obtain impersonal statistical data that is transferred to a third party for research, development or provision of services on behalf of the Company.

3.2.3. Categories of personal data subjects.

The personal data of the following subjects of personal data are processed:
- individuals who are the Users of the Website.

3.2.4. Personal data processed by the Company:
- data (namely, name and e-mail) received from the Website Users.

3.2.5. The personal data is processed:
– using automation tools;
– without using automation tools;

3.3. Storage of personal data.

3.3.1. Personal data of the subjects can be obtained, further processed and transmitted for storage electronically on the servers located in the Russian Federation.

3.3.2. Personal data of the subjects processed using automation tools for various purposes are stored in different folders.

3.3.3. Storage and placement of documents containing personal data in open electronic catalogues (file sharing) in ISPD shall not be allowed.

3.3.4. The storage of personal data in a form that allows to determine the subject of personal data is carried out no longer than the purpose of their processing requires, and they must be destroyed upon achievement of the processing goals or in case of loss of need to achieve them.

3.4. Destruction of personal data.

3.4.1. Personal data in electronic media is destroyed by erasing or formatting the media.

3.4.2. The fact of the destruction of personal data is documented by an act on the destruction of media and (or) data stored electronically.

3.5. Transfer of personal data.

3.5.1. The Company transfers personal data to the third parties in the following cases:
- the subject has expressed his consent to such actions;
- the transfer is envisaged by Russian or other applicable legislation within the framework of the procedure established by law.

3.5.2. The list of individuals to whom personal data is transmitted.
- anonymized personal data of the Website Users is transmitted to the Company’s counterparties.

4. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act ("CCPA") may provide you with rights that are in addition to those set forth elsewhere in this Privacy Policy regarding our use of your personal information. The CCPA Notice applies to "Consumers" as defined by the

Access to Information and Data Portability Rights

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
The categories of personal information we have collected about you.
The categories of sources from which we collected your personal information.
The business or commercial purposes for our collecting or selling your personal information.
The categories of third parties to whom we have shared your personal information.
The specific pieces of personal information we have collected about you.

A list of the categories of personal information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.

A list of the categories of personal information sold about you in the prior 12 months, or that no sale occurred. If we sold your personal information, we will explain:
• The categories of your personal information we have sold.
• The categories of third parties to which we sold personal information, by categories of personal information sold for each third party.

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.

Data Deletion Rights

Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.

5. Contacts

4.1. On issues regarding the Website’s operation, including requests on the processing of user personal data and (or) consent revocation to such processing, you can e-mail us at, as well as through the contact form on the website: