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hello@hotelassist.ru
hello@hotelassist.ru
Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by IE Mezhevykh N.K. (hereinafter referred to as the Operator).
1.1. The Operator's most important goal and condition for its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of rights to privacy, personal, and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://hotelassist.ru/.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases ensuring their accessibility on the Internet at the network address https://hotelassist.ru/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without additional information, the ownership of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual organizing and/or carrying out the processing of personal data independently or jointly with others, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://hotelassist.ru/.
2.9. Personal data permitted by the subject of personal data for distribution — personal data to which an unlimited number of persons have been granted access by the subject of personal data by giving consent to the processing of personal data permitted for distribution in accordance with the procedure provided by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://hotelassist.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data accessible to an unlimited group of persons, including publication of personal data in the media, posting on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — 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.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive from the subject of personal data reliable information and/or documents containing personal data;
— In case the subject of personal data withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the subject's consent if there are grounds specified in the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— Provide the subject of personal data, upon request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— Respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— Report to the authorized body for the protection of the rights of subjects of personal data, upon its request, the necessary information within 10 days from the date of receiving such a request;
— Publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions concerning personal data;
— Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— Perform other duties provided by the Personal Data Law.
4. Basic Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
— Obtain information regarding the processing of their personal data, except as provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and must not contain personal data related to other subjects of personal data, except in cases 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 clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
— Impose a condition of prior consent when processing 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 terminate the processing of personal data;
— Appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator in processing their personal data;
— Exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— Provide the Operator with accurate data about themselves;
— Notify the Operator of updates (changes) to their personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another subject of personal data without the latter's consent bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Processing Personal Data
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data relative to the stated purposes of processing is not permitted.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data are ensured in relation to the purposes of processing. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identification of the subject of personal data for no longer than required by the purposes of processing, unless the storage period is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or when the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Processing Personal Data:
Purpose of processing: Informing the User via email.
Personal data: Last name, first name, patronymic, email address, phone numbers.
Legal basis: The Operator's charter (foundation) documents.
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; sending informational emails to the email address.
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the subject of personal data to process their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to perform functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body, or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding an agreement initiated by the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.
7.5. Processing of personal data 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 subject of personal data are not violated.
7.6. Processing of personal data is carried out for personal data to which unlimited access has been provided by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Processing Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law agreement.
8.3. In case of inaccuracies in personal data, the User may update them independently by notifying the Operator via email to hello@hotelassist.ru with the subject line "Updating Personal Data."
8.4. The period for processing personal data is determined by achieving the purposes for which the personal data were collected, unless a different period is provided by the agreement or current legislation.
The User may at any time withdraw their consent to the processing of personal data by notifying the Operator via email to hello@hotelassist.ru with the subject line "Withdrawal of Consent to Process Personal Data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data is obliged to familiarize themselves with these documents independently. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions established by the subject of personal data on the transfer (except for granting access) and on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the subject of personal data for no longer than required by the purposes of processing, unless the storage period is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. Conditions for terminating the processing of personal data may include achieving the purposes of processing, expiration of the subject's consent, withdrawal of consent by the subject of personal data, a request to cease processing personal data, or detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions regarding the processing of their personal data by contacting the Operator via email at hello@hotelassist.ru.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://hotelassist.ru/en/privacy/.
1. General Provisions
This Personal Data Processing Policy is prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by IE Mezhevykh N.K. (hereinafter referred to as the Operator).
1.1. The Operator's most important goal and condition for its activities is to respect the rights and freedoms of individuals when processing their personal data, including the protection of rights to privacy, personal, and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://hotelassist.ru/.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases ensuring their accessibility on the Internet at the network address https://hotelassist.ru/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without additional information, the ownership of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual organizing and/or carrying out the processing of personal data independently or jointly with others, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://hotelassist.ru/.
2.9. Personal data permitted by the subject of personal data for distribution — personal data to which an unlimited number of persons have been granted access by the subject of personal data by giving consent to the processing of personal data permitted for distribution in accordance with the procedure provided by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://hotelassist.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data accessible to an unlimited group of persons, including publication of personal data in the media, posting on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — 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.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— Receive from the subject of personal data reliable information and/or documents containing personal data;
— In case the subject of personal data withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the subject's consent if there are grounds specified in the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— Provide the subject of personal data, upon request, with information regarding the processing of their personal data;
— Organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— Respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— Report to the authorized body for the protection of the rights of subjects of personal data, upon its request, the necessary information within 10 days from the date of receiving such a request;
— Publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions concerning personal data;
— Cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— Perform other duties provided by the Personal Data Law.
4. Basic Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right to:
— Obtain information regarding the processing of their personal data, except as provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form and must not contain personal data related to other subjects of personal data, except in cases 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 clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
— Impose a condition of prior consent when processing 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 terminate the processing of personal data;
— Appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction of the Operator in processing their personal data;
— Exercise other rights provided by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— Provide the Operator with accurate data about themselves;
— Notify the Operator of updates (changes) to their personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another subject of personal data without the latter's consent bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Processing Personal Data
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. Combining databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data relative to the stated purposes of processing is not permitted.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data are ensured in relation to the purposes of processing. The Operator takes necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identification of the subject of personal data for no longer than required by the purposes of processing, unless the storage period is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or when the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Processing Personal Data:
Purpose of processing: Informing the User via email.
Personal data: Last name, first name, patronymic, email address, phone numbers.
Legal basis: The Operator's charter (foundation) documents.
Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data; sending informational emails to the email address.
7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the subject of personal data to process their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to perform functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body, or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party, beneficiary, or guarantor, as well as for concluding an agreement initiated by the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.
7.5. Processing of personal data 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 subject of personal data are not violated.
7.6. Processing of personal data is carried out for personal data to which unlimited access has been provided by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Processing Personal Data
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law agreement.
8.3. In case of inaccuracies in personal data, the User may update them independently by notifying the Operator via email to hello@hotelassist.ru with the subject line "Updating Personal Data."
8.4. The period for processing personal data is determined by achieving the purposes for which the personal data were collected, unless a different period is provided by the agreement or current legislation.
The User may at any time withdraw their consent to the processing of personal data by notifying the Operator via email to hello@hotelassist.ru with the subject line "Withdrawal of Consent to Process Personal Data."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data is obliged to familiarize themselves with these documents independently. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Prohibitions established by the subject of personal data on the transfer (except for granting access) and on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the subject of personal data for no longer than required by the purposes of processing, unless the storage period is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. Conditions for terminating the processing of personal data may include achieving the purposes of processing, expiration of the subject's consent, withdrawal of consent by the subject of personal data, a request to cease processing personal data, or detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions regarding the processing of their personal data by contacting the Operator via email at hello@hotelassist.ru.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://hotelassist.ru/en/privacy/.