Privacy Policy

1. About this policy

This policy explains how we collect, use and protect the personal data of visitors to icngrow.com and ru.icngrow.com (the “Website”).

By using the Website and submitting a request, you confirm that you have read this policy. If you do not agree with it, please do not submit the form.

2. Who we are (data controller)

• Nord Gate LLC (Obshchestvo s ogranichennoy otvetstvennostyu «Nord Geit»)
• Primary State Registration Number (OGRN) 1079847144123, Taxpayer ID (INN) 7840378369
• Address: Office 516, 21 Nevsky Prospekt, Letter A, Saint Petersburg, 191186, Russia
• Privacy contact: dm@icngrow.com

3. What data we collect and why

Contact form data: your name, email address (English version) or phone number (Russian version), and company name if you provide it. We use it to respond to your request and discuss the program with you.

Technical data: IP address, browser and device information, date and time of the request. It is processed automatically to operate and secure the Website and to show you the right language version: your country is determined from your IP address on our own server, without sharing it with third parties.

We do not collect special categories of personal data, and we do not use web analytics or advertising trackers.

4. Legal basis

• Contact form data — your consent, given by ticking the checkbox in the form (Art. 6(1)(a) GDPR; Art. 6(1)(1) of Russian Federal Law No. 152-FZ).
• Technical data and the language cookie — our legitimate interest in running a secure, working website (Art. 6(1)(f) GDPR; Art. 6(1)(7) of Law No. 152-FZ).

5. Where and how data is processed

The Website is hosted on servers located in the Russian Federation. Requests are not stored in a website database: they are delivered to our team by email.

If you are located outside Russia (for example, in the EU/EEA), your data is transferred to Russia, which is not covered by an EU adequacy decision. We rely on your explicit consent for this transfer (Art. 49(1)(a) GDPR). We protect your data with appropriate technical and organisational measures, including HTTPS encryption and restricted access.

6. Who we share data with

We do not sell your data or share it with third parties for their own purposes. Data may only be shared with:

• Titan (Titan Email), the email service used to deliver form requests to us; its servers may be located outside Russia;
• public authorities, where required by law.

7. How long we keep data

Contact form data is kept for no longer than one (1) year after our last interaction with you, or until you withdraw your consent, whichever comes first, and is then deleted. Technical data is kept in server logs only as long as needed to operate and secure the Website.

8. Cookies

The Website uses a single functional cookie, lang, which remembers your language choice for one year. There are no advertising or analytics cookies. You can delete cookies in your browser settings; the Website will still work, but you will need to choose the language again.

9. Your rights

You have the right to:

• access your personal data and receive information about its processing;
• have inaccurate or incomplete data corrected;
• have your data erased or its processing restricted;
• object to processing based on legitimate interests;
• receive your data in a portable format;
• withdraw your consent at any time, without affecting earlier processing;
• lodge a complaint with a supervisory authority — in the EU/EEA, the authority in your country; in Russia, Roskomnadzor.

To exercise your rights or withdraw consent, email dm@icngrow.com. We will respond within 10 business days, and in any case within one month.

10. Changes to this policy

We may update this policy from time to time. The current version is always published on this page, with its effective date shown at the top.