Personal Data Processing Policy
1. General provisions
1.1. This Personal Data Processing Policy (hereinafter referred to as the Policy) has been developed in compliance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) in order to ensure the protection of human and civil rights and freedoms when processing personal data, including the protection of the right to privacy, personal and family secrets.
1.2. The Policy applies to all personal data processed by Novy Hotel LLC (TIN: 6950110563, OGRN: 1096952026544) (hereinafter referred to as the Operator).
1.3. The Policy applies to the relations in the field of personal data processing that arose with the Operator both before and after the approval of this Policy.
In compliance with the requirements of Part 2 of Article 18.1 of the Law on Personal Data, this Policy is published in free access on the Internet on the Operator's website at the network address: https://grandhotelzvezda.com/ru / (hereinafter referred to as the Website).
1.4. Basic concepts used in the Policy:
-personal data — any information related directly or indirectly to a specific or identifiable individual (hereinafter referred to as the Personal Data Subject), including information received from visitors and users (hereinafter referred to as the User) while using the Site.
— personal data operator (Operator) — an individual who independently or jointly with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data;
-personal data processing — any action (operation) or set of actions (operations) with personal data performed with or without automation tools. The processing of personal data includes, among other things: collection; recording; systematization; accumulation; storage; clarification (updating, modification); extraction; use; transfer (distribution, provision, access);
depersonalization; blocking; deletion; destruction.
-automated processing of personal data — processing of personal data using computer technology;
-dissemination of personal data — actions aimed at disclosing personal data to an unspecified group of people;
-provision of personal data — actions aimed at disclosing personal data to a certain person or a certain circle of people;
-blocking of personal data — temporary termination of the processing of personal data (except in cases where the processing is necessary to clarify personal data);
-destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed;
Depersonalization of personal data is an action that makes it impossible to determine whether personal data belongs to a specific Personal Data Subject without using additional information.;
— personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing;
— cookies are a small piece of text sent by the server and stored on the User's computer. Cookies allow you to collect data about browsing certain pages.;
— cross—border transfer of personal data is the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
1.6. Basic rights and obligations of the Operator.
1.6.1. The Operator has the right to:
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws;
- entrust the processing of personal data to another person with the consent of the Personal Data Subject, unless otherwise provided by federal law, on the basis of a contract concluded with this person. The person who processes personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided for by the Law on Personal Data;
-if the Personal Data Subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the Personal Data Subject, provided there are grounds specified in the Personal Data Act.
1.6.2. The Operator is obliged to:
-organize the processing of personal data in accordance with the requirements of the Law on Personal Data;
-respond to requests and requests from Personal Data Subjects and their legal representatives in accordance with the requirements of the Personal Data Act;
-notify the authorized body for the protection of the rights of Personal data Subjects (the Federal Service for Supervision of Communications, Information Technology and Mass Communications (Roskomnadzor)) upon request of this body, the necessary information is provided within 30 days from the date of receipt of such request.
1.7. Basic rights of the Personal data Subject. The personal data subject has the right to:
-receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the Personal Data Subject by the Operator in an accessible form, and it should not contain personal data related to other Personal Data Subjects, except in cases where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
-require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take legally prescribed measures to protect their rights.;
-to put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
-to appeal to Roskomnadzor or in court against illegal actions or omissions of the Operator during the processing of his personal data.
1.8. Control over the fulfillment of the requirements of this Policy is carried out by an authorized person responsible for organizing the processing of personal data by the Operator.
1.9. Responsibility for violation of the requirements of the legislation of the Russian Federation in the field of personal data processing and protection is determined in accordance with the legislation of the Russian Federation.
1.10. This Policy applies to all information that the Operator may receive about Site visitors.
2. Purposes of personal data collection
2.1. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. The operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal and family secrets. Processing of personal data incompatible with the purposes of personal data collection is not allowed.
2.2. Only personal data that meets the purposes of their processing is subject to processing.
2.3. The processing of personal data by the Operator is carried out for the following purposes::
- ensuring compliance with the Constitution of the Russian Federation, federal laws and other regulatory legal acts of the Russian Federation;
-informing the User by sending emails;
-implementation of civil law relations, including providing the User with access to the services, information and/or materials contained on the Site.
3.Consent to receive promotional newsletters
3.1. The Operator has the right to carry out promotional mailings and to process personal data of Website visitors for the specified purpose. By registering, the Site user agrees to receive promotional newsletters in the following ways::
a) by sending messages in messengers;
b) by sending letters to the email address.
4.Legal grounds for processing personal data
4.1. The legal basis for the processing of personal data is a set of regulatory legal acts, in compliance with which and in accordance with which the Operator processes personal data, including:
- The Constitution of the Russian Federation;
- The Civil Code of the Russian Federation;
- The Tax Code of the Russian Federation;
- Other regulatory legal acts regulating relations related to the Operator's activities.
The legal basis for the processing of personal data is also:
- contracts concluded between the Operator and Users;
- consent of the Subjects of personal data to the processing of their personal data.
5. Scope and categories of personal data processed, categories of Personal data Subjects
5.1. The content and scope of the personal data being processed must comply with the stated purposes of processing provided for in sec. 2 of this Policy. The personal data being processed should not be redundant in relation to the stated purposes of their processing.
5.2. The Operator may process personal data of the following categories of personal data subjects — the User of the Website: last name, first name, patronymic, contact phone number, e-mail address, other personal data provided by Users necessary for the conclusion and execution of contracts.
5.3. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, health status, intimate life, except in cases provided for by the legislation of the Russian Federation.
5.4. The Site also collects and processes anonymized visitor data (including cookies) using Internet statistics services (Yandex.Metrica, Yandex Webmaster), namely: IP address; information from cookies, browser information, access time to the site, page address, on which contains the ad block, the referrer (the address of the previous page), and other data.
This data is used to collect information about the actions of visitors on the site in order to improve its content, improve the functionality of the site and, as a result, create high-quality content and services for visitors.
The personal data subject can change his browser settings at any time so that all cookies are blocked or notified when they are sent. At the same time, the subject must understand that some functions and services of the Project will not be able to work properly.
6. Procedure and conditions of personal data processing
6.1. The processing of personal data is carried out by the Operator in accordance with the requirements of the legislation of the Russian Federation.
6.2. The processing of personal data is carried out with the consent of the Subjects of personal data to the processing of their personal data, as well as without it in cases provided for by the legislation of the Russian Federation.
6.3. The Operator performs both automated and non-automated processing of personal data.
6.4. The processing of personal data is carried out by the Operator personally.
6.5. Personal data is processed by:
- receiving personal data in writing directly from the Subjects of personal data;
- entering personal data into the logs, registers and information systems of the Operator;
- using other methods of personal data processing.
6.5.1. The Operator processes depersonalized User data if this is allowed in the User's browser settings (the storage of cookies and the use of JavaScript technology are enabled).
6.6. Disclosure and dissemination of personal data to third parties is prohibited without the consent of the Personal Data Subject, unless otherwise provided by federal law. Consent to the processing of personal data authorized by the Personal Data Subject for dissemination is issued separately from other consents of the Personal Data Subject to the processing of his personal data.
6.7. The requirements for the content of consent to the processing of personal data authorized by the Personal Data Subject for distribution are approved by Roskomnadzor Order No. 18 dated 02/24/2021.
6.8. The transfer of personal data to the bodies of inquiry and investigation, to the Federal Tax Service, the Pension Fund of the Russian Federation, the Social Insurance Fund and other authorized executive authorities and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
6.9. The Operator has the right to transfer data to third parties in the following cases::
- the transfer is necessary as part of the User's use of the Site's functionality;
- the transfer is required in accordance with the purposes of data processing;
— to protect the rights and legitimate interests of the Operator in connection with violations committed by the User.
6.10. The Operator takes the necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, distribution and other unauthorized actions, including:
-identifies threats to the security of personal data during their processing;
-develops documents regulating relations in the field of personal data processing and protection;
-creates the necessary conditions for working with personal data;
-organizes the accounting of documents containing personal data;
-organizes work with information systems in which personal data is processed;
-stores personal data in conditions that ensure their safety and exclude unauthorized access to them;
-organizes the training of the Operator's employees who process personal data.
6.11. The Operator stores personal data in a form that allows determining the Subject of personal data for no longer than the purposes of personal data processing require, unless the period of personal data storage is established by federal law or contract.
6.12.When collecting personal data, including through the Internet information and telecommunications network, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except for the cases specified in the Law on Personal Data.
6.13. In case of inaccuracies in personal data, the Personal Data Subject may update them independently by sending a notification to the Operator's e-mail address. info@grandhotelzvezda.com marked "Updating personal data".
6.14. The period of processing personal data is unlimited. The subject of personal data may at any time revoke his consent to the processing of personal data and the implementation of promotional newsletters by sending an e-mail notification to the Operator's e-mail address. info@grandhotelzvezda.com marked "Withdrawal of consent to the processing of personal data".
7. Updating, correcting, deleting and destroying personal data, responding to requests from subjects for access to personal data
7.1. Confirmation of the fact of personal data processing by the Operator, the legal grounds and purposes of personal data processing, as well as other information specified in Part 7 of Article 14 of the Law on Personal Data, are provided by the Operator to the Personal Data Subject or his representative when contacting or receiving a request from the Personal Data Subject or his representative.
The information provided does not include personal data related to other Subjects of Personal data, except in cases where there are legitimate grounds for the disclosure of such personal data.
The request must contain:
— the number of the main identity document of the Personal Data Subject or his representative, information about the date of issue of the specified document and the issuing authority;
— information confirming the Personal Data Subject's participation in the relationship with the Operator (contract number, date of conclusion of the contract, conditional designation and (or) other information), or information otherwise confirming the fact of personal data processing by the Operator;
-the signature of the Personal Data Subject or his representative.
The request can be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
If the request of the Personal Data Subject does not reflect all the necessary information in accordance with the requirements of the Law on Personal Data, or the subject does not have access rights to the requested information, a reasoned refusal is sent to him.
The right of a Personal data Subject to access his personal data may be restricted in accordance with Part 8 of Article 14 of the Law on Personal Data, including if the access of a Personal Data Subject to his personal data violates the rights and legitimate interests of third parties.
7.2. In case of detection of inaccurate personal data when contacting a Personal Data Subject or his representative, or at their request or at the request of Roskomnadzor, the Operator blocks personal data related to this personal data subject from the moment of such request or receipt of the specified request for the verification period, if blocking personal data does not violate the rights and legitimate interests of the subject personal data or third parties.
In case of confirmation of the inaccuracy of personal data, the Operator, based on information provided by the Personal Data Subject or his representative or Roskomnadzor, or other necessary documents, clarifies the personal data within seven working days from the date of submission of such information and removes the blocking of personal data.
7.3. In case of detection of unlawful processing of personal data when contacting (requesting) a Personal Data Subject or his representative or Roskomnadzor, the Operator shall block unlawfully processed personal data related to this personal data subject from the moment of such request or receipt of the request.
7.4. Upon achievement of the purposes of personal data processing, as well as in the case of withdrawal by the Personal data Subject of consent to their processing, personal data is subject to destruction if:
- nothing else is provided for by the contract to which the Personal Data Subject is a party, beneficiary or guarantor.;
- the operator does not have the right to process personal data without the consent of the Subject on the grounds provided for by the Law on Personal Data or other federal laws.;
— unless otherwise provided by another agreement between the Operator and the Subject of Personal data.
8.Additional information
8.1. This Policy may be changed or terminated unilaterally by the Operator without prior notice to the User. The new version of the Policy comes into force from the moment it is posted on the Website, unless otherwise provided by the new version of the Policy.
8.2. All suggestions or questions regarding this Privacy Policy should be sent by e-mail info@grandhotelzvezda.com /.