1. General provisions
This privacy policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, «On Personal Data» (hereinafter referred to as the Personal Data Law) and establishes the procedures for processing personal data and measures taken to ensure the security of personal data by LLC «Vladimir Agricultural Enterprise» (hereinafter referred to as the Operator).
1.1 The Operator sets compliance with the rights and freedoms of individuals as its primary goal and condition for carrying out its activities in personal data processing, including the protection of the rights to privacy, personal and family secrets.
1.2 This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about azhursuzdal.ru website visitors.
2. Key concepts related to the Privacy Policy
2.1 Automated processing of personal data — processing of personal data using computerized means or technology.
2.2 Website — a collection of graphic and informational materials, as well as computer programs and databases that provide their accessibility on the internet through the network address azhursuzdal.ru.
2.3 Personal data information system — a combination of personal data contained in databases and the information technologies and technical means that facilitate their processing.
2.4 Depersonalization of personal data — actions that result in the impossibility to determine the belonging of personal data to a particular User or other Data Subject without resorting to additional information.
2.5 Processing of personal data — any action (operation) or set of actions (operations), whether performed with or without the use of automation tools, involving personal data. These actions include collection, recording, organization, accumulation, storage, clarification (updating, modification), extraction, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.6 Operator — state body, municipal body, legal entity or an individual, that organizes and processes personal data independently or jointly with other persons, and determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.7 Personal data — any information that directly or indirectly relates to a specific or identifiable User of azhursuzdal.ru website.
2.8 Personal data authorized by the Data Subject for distribution — personal data of a Data Subject, that the Data Subject has given their consent to be distributed and to be available to an unlimited number of persons in accordance with the procedure provided for by the Personal Data Law (hereinafter – personal data authorized for distribution).
2.9 User — any visitor of azhursuzdal.ru website.
2.10 Disclosure of personal data — actions aimed at revealing personal data to a specific individual or a specific group of individuals.
2.11 Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of individuals (personal data transfer) or making personal data available to an unlimited number of persons. These actions may include, but are not limited to, publication of personal data in mass media, posting in information and telecommunications networks or providing access to personal data by any other means.
2.12 Cross-border personal data transfer — the transfer of personal data onto the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.13 Destruction of personal data — any actions that result in permanent deletion of personal data with inability of further restoration and (or) the destruction of physical personal data storage devices.
3. Main rights and obligations of the Operator
3.1 The Operator has the right to:
• obtain true and reliable personal data and/or documents containing personal data from the Data Subject;
• resume personal data processing without the consent of the Data Subject on the grounds stated in Personal Data Law in the event the Data Subject withdraws consent to the personal data processing;
• identify the structure and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and other relevant regulatory legal acts independently, unless otherwise provided by the Personal Data Law or other federal laws.
3.2 The Operator is obliged to:
• provide the Data Subject with information concerning the processing of their personal data at their request;
• process personal data in accordance with the procedure established by the current legislation of the Russian Federation;
• respond to requests from Data Subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the Data Protection Authority with the necessary information within 30 days from the date of receiving such a request;
• publish or otherwise provide unrestricted access to this Privacy 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, sharing, and other illegal actions with respect to personal data;
• cease the personal data transfer (distribution, sharing, access), stop processing and erase the personal data under the procedure and in the cases provided for by the Personal Data Law;
• fulfill other duties stipulated by the Personal Data Law.
4. Basic rights and obligations of Data Subjects
Data Subjects have the right to:
• obtain information concerning the processing of their personal data, except in cases provided for by federal laws. The information provided to the Data Subject by the Operator shall be in accessible form, it should not contain personal data related to other Data Subjects expect in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established in the Personal Data Law;
• request the Operator to clarify their personal data, to have it blocked or destroyed if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated processing purposes, as well as to take legal measures to protect their rights as provided by law.;
• require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market.
• withdraw consent for the processing of personal data;
• appeal to the Data Protection Authority, or appeal in court against illegal actions or inaction of the Operator when processing their personal data;
• exercise other rights provided for by the legislation of the Russian Federation.
4.2 Data Subjects shall be obliged to:
• provide the Operator with reliable data about themselves;
• inform the Operator about any modifications (update, change) of their personal data.
Individuals who have provided the Operator with false information about themselves or information about another Data Subject without their consent shall be liable in accordance with the legislation of the Russian Federation.
5. The Operator may process the following personal data of the User
5.1 Last name, first name, patronymic.
5.2 Phone number.
5.3 Please note that the website also collects and processes anonymous user data (including cookies) via internet statistics services, such as Yandex Metrica, LiveTex, TravelLine.
5.4 The data mentioned throughout the text of the Policy are collectively referred to as Personal Data.
5.5 The Operator does not process special categories of personal data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.
5.6 Processing of personal data authorized for distribution from the special categories of personal data specified in Part 1, Article 10 of the Personal Data Protection Law is allowed if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Protection Law are observed.
5.7 The User’s consent for the processing of personal data authorized for distribution is obtained separately from other consents for the processing of their personal data. At the same time, the conditions stipulated, in particular, in Article 10.1 of the Personal Data Protection Law, are observed. The requirements for the content of such consent are established by the Data Protection Authority.
5.7.1 The User provides their consent for the processing of personal data authorized for distribution directly to the Operator.
5.7.2 The Operator is obliged, within a period not exceeding three business days from the moment of receiving the User’s consent, to publish information on the processing conditions, the existence of prohibitions and conditions on the processing of personal data authorized for distribution by an unlimited number of individuals.
5.7.3 The transfer (distribution, provision, access) of personal data authorized for distribution by the Data Subject must be terminated at any time upon the Data Subject’s request. This requirement should include the full name, contact information (phone number, email address, or mailing address) of the Data Subject, as well as a list of personal data that is subject to termination. The personal data specified in this request can only be processed by the Operator to whom it was sent.
5.7.4 The consent for processing personal data authorized for distribution shall terminate from the moment the Operator receives the request specified in clause 5.7.3 of this Policy regarding the processing of personal data.
6. Principles of personal data processing
6.1 The Operator shall process personal data on a legal and fair basis.
6.2 Personal data processing is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which the personal data was collected is not permitted.
6.3 Merging of databases that contain personal data processed for incompatible purposes is not allowed.
6.4 Only personal data that meets the purposes of their processing is subject to processing.
6.5 The contents and the volume of the processed personal data shall correspond to the stated purposes of processing. Excessiveness of the processed personal data in relation to the stated purposes of their processing is not allowed.
6.6 When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.
6.7 Personal data shall be stored in a form that allows identifying the Data Subject for no longer than it is necessary for the purposes of personal data processing, unless the storage period is established by federal law or/and a contract to which the Data Subject is a party, beneficiary or guarantor. The processed personal data shall be destroyed or depersonalized upon reaching the purposes of processing or in case it is no longer necessary to reach the said purposes, unless otherwise provided by federal law.
7. Purposes of personal data processing
7.1 Purpose of processing the User’s personal data:
• informing the User by sending emails;
• conclusion, execution and termination of civil law contracts;
• providing the User with access to the services, information and/or materials contained on azhursuzdal.ru website.
7.2 The Operator also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always revoke their agreement to receive notification messages from the Operator by sending an email to booking@azhursuzdal.ru under the subject «Unsubscribe from newsletters, services and special offers».
7.3 Depersonalized User data collected using Internet statistics services are used to collect information about User activity on the website, improve the quality of the website and its content.
8. Legal grounds for processing personal data
8.1 The legal grounds for processing personal data by the Operator are:
• statutory (constituent) documents of the Operator;
• federal laws and other regulatory legal acts in the field of personal data protection;
• User’s consent for the processing of their personal data, including the processing of personal data authorized for distribution.
8.2 The Operator shall process the User’s personal data only if they are filled out and/or submitted by the User themselves through special forms located on azhursuzdal.ru website or sent to the Operator via email. By filling out the respective forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.
8.3 The Operator processes depersonalized data about the User if the User’s browser settings allow for it.
8.4 The Data Subject shares their personal data independently and consents voluntarily, freely and in their own interest.
9. Terms of personal data processing
9.1 Personal data processing is carried out with the consent of the Data Subject for the processing of their personal data.
9.2 Personal data processing is necessary to achieve the purposes provided for by the international treaty of the Russian Federation or by law, to execute functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.
9.3 Personal data processing is necessary for the execution of the contract to which the Data Subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the Data Subject, or a contract under which the Data Subject will be a beneficiary or guarantor.
9.4 Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to fulfill important public interests, provided that the rights and freedoms of the Data Subject are not violated.
9.5 Processing is carried out for personal data that is made publicly available by the Data Subject themselves or at their request, and such data is accessible to an unlimited number of individuals (hereinafter referred to as publicly available personal data).
10. Procedure for collecting, storing, transmitting, and performing other types of personal data processing
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.
10.1 The Operator shall ensure the integrity and confidentiality of personal data by taking all possible measures to prevent unauthorized access to personal data.
10.2 The User’s personal data will never be transferred to third parties under any circumstances, except in cases related to the fulfillment of applicable legislation or when the Data Subject has given their consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
10.3 In case the User identifies inaccuracies in their personal data, the User may update it themselves by sending a notification to the Operator’s email booking@azhursuzdal.ru under the subject «Personal Data Update».
10.4 The terms of personal data processing are determined by the period necessary to achieve the purposes for which the personal data was collected, unless a different period is specified in the contract or required by applicable legislation.
The User can revoke their consent to the personal data processing at any time by sending a notification to the Operator’s email address booking@azhursuzdal.ru under the subject «Withdrawal of consent for personal data processing».
10.5 All information collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by these actors (Operators) in accordance with their User Agreement and Privacy Policy. Data Subject and / or User is obliged to familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of the third parties, including the service providers specified in this paragraph.
10.6 The prohibitions imposed by the Data Subject on the transfer (except for providing access) and the processing or conditions of processing (except for obtaining access) of personal data authorized for distribution do not apply in cases of processing personal data in the public interest, as defined by Russian legislation.
10.7 The Operator shall ensure the confidentiality of personal data when processing personal data.
10.8 The Operator shall store personal data in a form that allows identifying the Data Subject for no longer than necessary for the purposes of personal data processing, unless the storage period is established by federal law or/and the contract to which the Data Subject is a party, beneficiary or guarantor.
10.9 The termination of personal data processing may occur upon achieving the purposes of processing, expiration of the consent period provided by the Data Subject, withdrawal of consent by the Data Subject, or the identification of unauthorized processing of personal data.
11. List of actions performed by the Operator with the personal data obtained
11.1 The Operator collects, records, systematizes, accumulates, stores, specifies (updates, changes), extracts, uses, transfers (distributes, provides access) depersonalizes, blocks, deletes and destroys personal data.
11.2 The Operator carries out automated processing of personal data, including the collection and/or transfer of information, using information and telecommunication networks or without them.
12. Cross-border personal data transfer
12.1 Before initiating the cross-border transfer of personal data, the Operator is obliged to ensure that the legislation of the foreign state to which the personal data is to be transferred provides reliable protection of the Data Subject rights.
12.2 The cross-border transfer of personal data to foreign countries that do not meet the aforementioned requirements may only be carried out if there is written consent from the Data Subject for the cross-border transfer of their personal data and/or in the event of the contract of which the Data Subject is a party.
13. Personal data privacy
The Operator and other individuals who have gained access to personal data shall not distribute or disclose personal data without the consent of the Data Subject, unless otherwise provided by federal law.
14. Final provisions
14.1 The User may contact the Operator at booking@azhursuzdal.ru to get more details concerning personal data processing.
14.2 This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
14.3 The current version of the Policy is freely available on the Internet at https://en.azhursuzdal.ru/policy/
Azhur SH hotel Suzdal
Suzdal, Lenin st., 82
Tel.: 8 (800) 301-35-80
Tel.: 8 (49231) 23-888
Tel.: 8 (910) 179-64-58
booking@azhursuzdal.ru