Personal data processing policy

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter, the Personal Data Law) and sets out the procedure for processing personal data and the measures taken by Individual Entrepreneur Yuri Gennadyevich Milaev (hereinafter, the Operator) to ensure the security of personal data.

1.1. The Operator's foremost objective and a condition for carrying out its activities is to observe the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy and to personal and family confidentiality.

1.2. This Operator's policy regarding the processing of personal data (hereinafter, the Policy) applies to all information that the Operator may obtain about visitors to the website https://arthotel30.ru.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data means the processing of personal data by means of computer technology.

2.2. Blocking of personal data means the temporary suspension of the processing of personal data (except where processing is necessary to rectify personal data).

2.3. Website means the set of graphic and informational materials, as well as computer programs and databases, that make them available on the internet at the network address https://arthotel30.ru.

2.4. Personal data information system means the set of personal data contained in databases, together with the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data means actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belong to a specific User or other personal data subject.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, erasure and destruction of personal data.

2.7. Operator means a state body, municipal body, legal entity or individual that, alone or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of processing personal data, the categories of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://arthotel30.ru.

2.9. Personal data authorized by the data subject for dissemination means personal data to which the data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized by the data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter, personal data authorized for dissemination).

2.10. User means any visitor to the website https://arthotel30.ru.

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

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the publication of personal data in the mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a public authority of a foreign state, or to a foreign individual or foreign legal entity.

2.14. Destruction of personal data means any actions as a result of which personal data are irreversibly destroyed so that the content of the personal data cannot subsequently be restored in the personal data information system, and/or the physical media containing personal data are destroyed.

3. Key Rights and Obligations of the Operator

3.1. The Operator has the right to:

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

- if the data subject withdraws consent to the processing of personal data or submits a request to stop processing personal data, continue processing the personal data without the data subject's consent where there are grounds specified in the Personal Data Law;

- independently determine the composition and list of measures necessary and sufficient to ensure fulfilment of the obligations provided for by the Personal Data Law and the regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

- provide the data subject, at their request, with information concerning the processing of their personal data;

- organize the processing of personal data in the manner established by the applicable legislation of the Russian Federation;

- respond to appeals and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

- provide the authorized body for the protection of the rights of personal data subjects (Roskomnadzor, the Russian data protection authority), at its request, with the necessary information within 10 days from the date of receipt of such request;

- publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

- take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision or dissemination, as well as against other unlawful actions in relation to personal data;

- stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;

- perform other obligations provided for by the Personal Data Law.

4. Key Rights and Obligations of Data Subjects

4.1. Data subjects have the right to:

- receive information concerning the processing of their personal data, except in cases provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form and must not contain personal data relating to other data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

- require the Operator to rectify, block or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;

- make prior consent a condition for the processing of personal data for the purpose of promoting goods, works and services on the market;

- withdraw consent to the processing of personal data and submit a request to stop processing personal data;

- appeal against unlawful actions or omissions of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;

- exercise other rights provided for by the legislation of the Russian Federation.

4.2. Data subjects are obliged to:

- provide the Operator with accurate information about themselves;

- notify the Operator of any rectification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data are processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting the personal data is not permitted.

5.3. Combining databases containing personal data processed for purposes that are incompatible with each other is not permitted.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Processing of personal data that is excessive in relation to the stated purposes of processing is not permitted.

5.6. When personal data are processed, their accuracy, sufficiency and, where necessary, relevance to the purposes of processing are ensured. The Operator takes, and/or ensures that others take, the necessary measures to delete or rectify incomplete or inaccurate data.

5.7. Personal data are stored in a form that allows the data subject to be identified for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized once the purposes of processing have been achieved or if the need to achieve those purposes no longer exists, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

The Operator processes the personal data of Website Users solely for the purposes of providing hotel services, informing Users about new products/services (including by telephone/email), and sending replies to guests' enquiries.

The following personal data of Users are collected and processed on the Website:

- personal details (surname, first name, patronymic, day, month and year of birth);

- contact telephone number;

- email address.

7. Conditions for Processing Personal Data

7.1. Personal data are processed with the data subject's consent to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice or the enforcement of a judicial act or an act of another body or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the data subject are not violated.

7.6. Personal data are processed to which access by an unlimited number of persons has been granted by the data subject or at their request (hereinafter, publicly available personal data).

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

8. Procedure for the Collection, Storage, Transfer and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the applicable legislation on personal data protection.

8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.

8.3. If inaccuracies are found in the personal data, the User may update them independently by sending a notice to the Operator's email address info@arthotel30.ru marked "Updating of personal data".

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator by email to the Operator's email address info@arthotel30.ru marked "Withdrawal of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, communication providers and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or the User must independently and in a timely manner familiarize themselves with those documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

8.6. Prohibitions established by the data subject on the transfer (other than providing access) of personal data authorized for dissemination, and on the processing or conditions of processing (other than obtaining access) of such data, do not apply in cases where personal data are processed in state, public and other public interests as defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

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

8.9. Grounds for terminating the processing of personal data may include the achievement of the purposes of processing, the expiry of the data subject's consent, the withdrawal of consent by the data subject or a request to stop processing personal data, as well as the detection of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Obtained

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, erasure and destruction of personal data.

9.2. The Operator carries out automated processing of personal data, with or without receiving and/or transmitting the information obtained via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfers of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties or disseminate them without the consent of the data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarification on matters of interest concerning the processing of their personal data by contacting the Operator.

Requests from data subjects regarding the processing of their personal data by the Operator are accepted at: 414000, Astrakhan, ul. Kirova 87, 3rd floor, ART Hotel. Data subjects may also send their request, signed with an enhanced electronic signature, to the email address: info@arthotel30.ru. Requests are considered within no more than 10 (ten) days from the date of receipt.

13. Cookies, Analytics Services and Guest Reviews

13.1. The Website uses cookies that are necessary for its operation, for example to remember the User's response to the cookie notice. Such files do not contain personal data.

13.2. With the User's consent, given by clicking the "Accept" button in the cookie notice, the following web analytics services are enabled on the Website: Yandex Metrica (Yandex LLC, Russia) and, if used, Google Analytics (Google LLC, USA). These services collect depersonalized visit data: IP address, browser and device information, pages viewed and time of visit. Purpose: improving the Website's performance and assessing the effectiveness of advertising. If the User clicks "Decline", the analytics services are not enabled. The decision can be changed by deleting cookies and site data in the browser settings.

13.3. Through the review form on the Website, the Operator receives the guest's name, review text, rating and telephone number or email address. Purpose of processing: verifying that the review was left by a guest of the hotel, and publishing the review. The telephone number and email address are not published on the Website and are used only for verification. The data are stored until the review is deleted or until consent is withdrawn in the manner set out in section 12.

13.4. Through the request form on the Website (accommodation for a company and other requests), the Operator receives the name, phone number or email address, the preferred date, the number of guests and any wishes. Purpose of processing: to contact the User, select services and calculate the price. Request details are passed to the hotel front desk, including via the Telegram messenger. The name and contact details are deleted no later than 180 days after the request.