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Regulation on the collection, storage, processing and protection of personal data of users of the website «Azheur Hotel Suzdal», published on the Internet at «https://azhursuzdal.ru/» (hereinafter – the «Website»).
This Privacy Policy for Personal Data (hereinafter – the «Privacy Policy», the «Regulation») applies to all information that the Website may obtain about the User during the use of the Website.
In this Regulation on the collection, storage, processing and protection of personal data of Website users (hereinafter – the «Regulation»), the following terms are used:
1.1. «Website Administration» – authorized employees managing the Website, acting on behalf of the Limited Liability Company «Vladimirskoye Agricultural Enterprise», INN 3329042803, OGRN 1073340001074, legal address: Vladimir, Yuryevskaya St., bld. 2, floor 3, room 303, actual address: Vladimir region, Suzdal, Lenina St., bld. 82, who organize and/or carry out the processing of personal data, and also determine the purposes of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
1.2. «Personal Data» – any information relating directly or indirectly to a specific or determinable natural person (personal data subject).
1.3. «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 (update, change), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
1.4. «Distribution of Personal Data» – actions aimed at disclosing personal data to a certain circle of persons with prior consent, and in cases provided for by law and/or this Policy;
1.5. «Provision of Personal Data» – actions aimed at disclosing personal data to a specific person or a specific circle of persons;
1.6. «Blocking of Personal Data» – temporary suspension of processing of personal data (except in cases where processing is necessary to clarify personal data).
1.7. «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.
1.8. «Anonymization of Personal Data» – actions as a result of which it becomes impossible without the use of additional information to determine the ownership of personal data to a specific personal data subject.
1.9. «Confidentiality of Personal Data» – a mandatory requirement for the Operator or other person who has gained access to personal data not to allow their distribution without the consent of the personal data subject or other legal grounds.
1.10. «Operator» – a person or organization that independently organizes the processing of personal data, and also determines the purposes of processing personal data subject to processing, and the actions (operations) performed with personal data. The Operator is: LLC «Vladimirskoye Agricultural Enterprise» (INN 3329042803, OGRN 1073340001074, legal address: Vladimir, Yuryevskaya St., bld. 2, floor 3, room 303, actual address: Vladimir region, Suzdal, Lenina St., bld. 82).
1.11. «Website User» (hereinafter – the «User») – a person who has access to the Website via the Internet and uses the Website, including, but not limited to, being a Buyer of the Website’s services.
1.12. «Automated Processing of Personal Data» – processing of personal data using computer technology.
1.13. «Personal Data Information System» (PDIS) – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
1.14. «Federal Law» (FL) – Federal Law No. 152-FZ of July 27, 2006 «On Personal Data» (hereinafter – the «Personal Data Law»).
1.15. «Cookies» – a small piece of data sent by a web server and stored on the user’s computer, which the web client or web browser sends back to the web server each time in an HTTP request when attempting to open a page of the corresponding website/application.
1.16. «IP Address» – a unique network address of a node in a computer network built on the IP protocol.
2.1. The User’s use of the Website constitutes acceptance of this Regulation and the terms of processing of the User’s personal data.
2.2. In case of disagreement with the terms of the Regulation, the User must stop using the Website.
2.3. This Regulation applies only to the Website owned by LLC «Vladimirskoye Agricultural Enterprise» (INN 3329042803, OGRN 1073340001074), and does not control and is not responsible for third-party websites/applications that the User may access via links available on the Website.
2.4. The Website Administration does not verify the accuracy of personal data provided by the Website User.
2.5. The Regulation on the collection, storage, processing and protection of personal data of Website Users (hereinafter – the «Regulation») has been developed in order to comply with the requirements of the legislation of the Russian Federation containing personal data and to identify Website Users.
2.6. The Regulation has been developed in accordance with the Constitution of the Russian Federation, the Civil Code of the Russian Federation, and the current legislation of the Russian Federation in the field of personal data protection.
2.7. The Regulation establishes the procedure for processing personal data of Website Users: actions for collection, systematization, accumulation, storage, clarification (update, change), destruction, anonymization of personal data.
2.8. Principles of personal data processing:
2.9. Conditions for processing personal data.
2.9.1. Processing of personal data of Website Users is carried out on the basis of the Civil Code of the Russian Federation, the Constitution of the Russian Federation, and the current legislation of the Russian Federation in the field of personal data protection.
2.9.2. Processing of personal data of Website Users is carried out in compliance with the principles and rules provided for by the Regulation and the legislation of the Russian Federation.
2.9.3. Processing of personal data is permitted in the following cases:
2.9.4. Processing of personal data.
Processing of personal data of Website Users is carried out for the purpose of providing the User with the opportunity to interact with the Website, as well as to achieve the purposes set out in Section 4 of the Regulation.
Information constituting personal data on the Website is any information relating to a specific or determinable natural person (personal data subject) on the basis of such information.
2.10. Sources of obtaining personal data of Users.
The source of information about all personal data of the User is the User himself.
The source of information about the User’s personal data is the information obtained as a result of the Operator providing the User with the rights to use the Website.
Personal data of Users is confidential information with restricted access.
Ensuring the confidentiality of personal data is not required in case of their anonymization, as well as in relation to publicly available personal data.
The Operator does not have the right to collect and process the User’s personal data about his racial or national origin, political views, religious or philosophical beliefs, private life, except in cases provided for by current legislation.
The Operator does not have the right to receive and process the User’s personal data about his membership in public associations or his trade union activities, except in cases provided for by Federal Law.
2.11. Methods of processing personal data.
Processing of the User’s personal data is carried out by any lawful means, including in personal data information systems with or without the use of automation tools.
The User agrees that the Website Administration has the right to transfer personal data to third parties with whom the Operator has concluded an agreement on the basis of which it entrusts the processing of personal data to another person. An essential condition of such agreement is the list of actions (operations) with personal data that will be performed by the person processing personal data, the purposes of processing, the obligation of such person to ensure the confidentiality of personal data and the security of personal data during their processing, and the requirements for the protection of processed personal data must also be specified in accordance with Article 19 of the Federal Law «On Personal Data» No. 152-FZ of July 27, 2006. The transfer of data to these third parties is due to the fulfillment of the Website’s obligations and the achievement of data processing purposes.
The User’s personal data may be transferred to authorized state authorities of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation.
In the event of loss or disclosure of personal data, the Website Administration notifies the User of the loss or disclosure of personal data.
The Website Administration takes the necessary organizational and technical measures to protect the User’s personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.
The Website Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.
2.12. Rights of personal data subjects (Users).
2.12.1. The User has the right to receive information about the Operator, about its location, about the Operator’s possession of personal data relating to a specific personal data subject (User), as well as to access such personal data, except for cases provided for by Part 8 of Article 14 of the Personal Data Law.
2.12.2. The User has the right to receive from the Operator, upon personal application to it or upon receipt by the Operator of a written request from the User, the following information regarding the processing of his personal data, including containing:
2.12.3. The User has the right to appeal to the authorized body for the protection of the rights of personal data subjects or in court the actions or inaction of the Operator if he believes that the latter processes his personal data in violation of the requirements of the Federal Law «On Personal Data» or otherwise violates his rights and freedoms.
2.12.4. The personal data subject has the right to protect his rights and legitimate interests, including compensation for losses and/or compensation for moral damage in court, provided that the Operator’s guilt is established by the court.
2.13. Confidentiality regime for personal data.
2.13.1. The Operator ensures the confidentiality and security of personal data during their processing in accordance with the requirements of the legislation of the Russian Federation.
2.13.2. The Operator does not disclose to third parties and does not distribute personal data without the consent of the personal data subject, unless otherwise provided for by Federal Law or specified in this Regulation.
The User agrees that the Website Administration has the right to transfer personal data to third parties with whom the Operator has concluded an agreement on the basis of which it entrusts the processing of personal data to another person. An essential condition of such agreement is the list of actions (operations) with personal data that will be performed by the person processing personal data, the purposes of processing, the obligation of such person to ensure the confidentiality of personal data and the security of personal data during their processing, and the requirements for the protection of processed personal data must also be specified in accordance with Article 19 of the Federal Law «On Personal Data» No. 152-FZ of July 27, 2006. The transfer of data to these third parties is due to the fulfillment of the Website’s obligations and the achievement of data processing purposes.
The User’s personal data may be transferred to authorized state authorities of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation.
In the event of loss or disclosure of personal data, the Website Administration notifies the User of the loss or disclosure of personal data.
2.13.3. In accordance with the list of personal data processed on the Website, the personal data of Website Users is confidential information.
2.13.4. Persons processing personal data are obliged to comply with the requirements of the Operator’s governing documents regarding ensuring the confidentiality and security of personal data.
2.13.5. The Website does not control and is not responsible for third-party websites that the User may access via links available on the Website.
3.1. This Regulation establishes the obligations of the Website Administration to non-disclosure and to ensure the protection regime for the confidentiality of personal data that the User provides at the request of the Website Administration when booking on the Website or when performing other actions on the Website, and also establishes the main provisions and conditions for the collection, storage, processing and protection of personal data of Website Users.
3.2. Personal data permitted for processing within the framework of this Privacy Policy is provided by the User by filling out the booking form, as well as the «Buy certificate», «Submit a request», «Subscribe» tabs on the website «Azheur Hotel Suzdal», published on the Internet at «https://azhursuzdal.ru/», and includes the following information – hereinafter «personal data»:
3.3. The Website protects Data that is automatically transmitted during the viewing of advertising blocks and when visiting pages on which the statistical script of the system («pixel») is installed:
3.3.1. Disabling cookies may result in the inability to access parts of the Website that require authorization.
3.3.2. The Website collects statistics on the IP addresses of its visitors. This information is used to identify and solve technical problems, and to monitor the legality of financial payments.
3.4. Any other personal information not specified above (booking history, browsers and operating systems used, etc.) is subject to secure storage and non-distribution, except for cases provided for in clause 2.13.2. of this Privacy Policy.
3.5. Persons entitled to access personal data.
3.5.1. The right of access to personal data of subjects is held by persons vested with appropriate authority in accordance with their official duties.
3.5.2. The list of persons having access to personal data is approved by the Operator.
3.6. Any other personal information not specified above (browsers and operating systems used, etc.) is subject to secure storage and non-distribution, except for cases provided for in clause 2.13.2. of this Privacy Policy.
3.7. Legal grounds for processing personal data:
3.7.1. The Operator processes the User’s personal data only if they are sent by the User through the forms located on the Website. By sending his personal data to the Operator, the User expresses his consent to this Policy.
3.7.2. The Operator processes anonymized data about the User if this is permitted in the User’s browser settings (saving «cookie» files is enabled).
4. PURPOSES OF COLLECTING THE USER’S PERSONAL INFORMATION AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
4.1. The Website Administration may use the User’s personal data for the following purposes:
4.1.1. Anonymized data of Users collected using an Internet statistics service is used to collect information about Users’ actions on the Website, to improve the quality of the Website and its content.
4.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the Website.
4.2.1. By filling out the appropriate forms and/or sending his personal data to the Operator, the User expresses his consent to this Regulation.
4.2.2. The Operator processes anonymized data about the User if this is permitted in the User’s browser settings (saving «cookie» files is enabled).
5.1. Processing of the User’s personal data is carried out by any lawful means, including in personal data information systems with or without the use of automation tools.
5.2. The User’s personal data may be transferred to authorized state authorities of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation.
5.3. In the event of loss or disclosure of personal data, the Website Administration notifies the User of the loss or disclosure of personal data.
5.4. The Website Administration takes the necessary organizational and technical measures to protect the User’s personal data from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.
5.5. The terms of processing and storage of personal data of Users on the Website are unlimited and come into effect from the moment of acceptance (acceptance) by the User of this Regulation on the Website and remain in effect until the natural person (User) unsubscribes from advertising, news, information newsletters and messages. Also, processing of personal data may be terminated upon the request of the personal data subject.
The terms of processing and storage of personal data of Users on the Website also remain in effect until the User declares his desire to delete his personal data from the Website and/or withdraw his consent to the processing of personal data. The User has the right to withdraw his consent to the processing of personal data at any time by sending a notice to the Operator (Website Administration) at the Operator’s address (Website Administration of LLC «Vladimirskoye Agricultural Enterprise» (INN 3329042803, OGRN 1073340001074, legal address: Vladimir, Yuryevskaya St., bld. 2, floor 3, room 303, actual address: Vladimir region, Suzdal, Lenina St., bld. 82, booking@azhursuzdal.ru, 8-(800)-301-35-80).
The User expresses his consent to the terms of this Regulation and to the processing of his personal data by acceptance (acceptance), expressed in placing a mark in the form of a «web tag» on the Website in the fields: «I give consent to the processing of my personal data«; «I agree to the terms of the Regulation on the collection, storage, processing and protection of personal data» (Privacy Policy) by clicking the «Submit» button or similar in content on the Website with the original meaning preserved, which is understood as consent.
5.6. In the event of deletion of data from the Website on the initiative of one of the parties, namely the termination of use of the Website, the User’s personal data is stored in the Operator’s databases for five years in accordance with the legislation of the Russian Federation.
After the expiration of the above period of processing and storage of the User’s personal data, the User’s personal data is automatically deleted by an algorithm set by the Operator.
The Operator does not process personal data of Users on paper media.
5.7. Blocking of personal data.
5.7.1. Blocking of personal data means the temporary suspension by the Operator of operations for their processing at the User’s request when the User identifies inaccuracies in the processed information or, in the opinion of the personal data subject, unlawful actions in relation to his data.
5.7.2. The Operator does not transfer personal data to third parties and does not entrust the processing of personal data to third parties and organizations, except for the cases in clauses 2.13.2, 5.9 of this Policy, and the provision of the User’s consent to the transfer of his personal data for processing to third parties – strategic partners with whom the Operator has concluded an Agreement and to whom the Operator transfers personal data to fulfill the purposes specified in this consent, namely: recording, systematization, accumulation, storage, clarification (update, change), retrieval, use, transfer (provision, access), anonymization, blocking, deletion, destruction of personal data. In other cases, personal data of Website Users is processed only by employees of the Operator (database administrators, etc.) authorized in accordance with the established procedure to process personal data of Users.
5.7.3. Blocking of personal data on the Website is carried out on the basis of a written application from the personal data subject.
5.8. Destruction of personal data.
5.8.1. Destruction of personal data means actions as a result of which it becomes impossible to restore the content of personal data on the Website and/or as a result of which the material carriers of personal data are destroyed.
5.8.2. The personal data subject has the right to demand in writing the destruction of his personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing. The personal data subject has the right to unilaterally withdraw his consent to the processing of personal data in writing.
5.8.3. In the absence of the possibility of destroying personal data, the Operator blocks such personal data.
5.8.4. Destruction of personal data is carried out by erasing information using certified software with guaranteed destruction (in accordance with the specified characteristics for the installed software with guaranteed destruction).
5.9. The User agrees that the Website Administration has the right to transfer personal data to third parties with whom the Operator has concluded an Agreement for the purposes of advertising and/or information mailing, subject to the User’s consent to the provision of such mailings to him and for the fulfillment of other processing purposes.
5.10. Cross-border transfer of personal data is not carried out.
6.1. Ensuring the security of personal data is achieved, in particular, by:
6.1.1. Identification of threats to the security of personal data during their processing in personal data information systems;
6.1.2. Application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems, necessary to meet the requirements for the protection of personal data;
6.1.3. Application of information security tools that have passed the conformity assessment procedure in the established manner;
6.1.4. Assessment of the effectiveness of measures taken to ensure the security of personal data prior to the commissioning of the personal data information system;
6.1.5. Accounting of machine media of personal data;
6.1.6. Detection of facts of unauthorized access to personal data and taking measures;
6.1.7. Restoration of personal data modified or destroyed due to unauthorized access to it;
6.1.8. Establishment of access rules to personal data processed in the personal data information system, as well as ensuring registration and recording of all actions performed with personal data in the personal data information system;
6.1.9. Control over measures taken to ensure the security of personal data and the level of protection of personal data information systems.
6.1.10. Installation of certified anti-virus software with regularly updated databases.
6.1.11. Detection of facts of unauthorized access to personal data and taking measures.
6.2. The Operator ensures the safety of personal data transferred to it and takes all possible measures to prevent unauthorized persons from accessing personal data.
7.1. The User is obliged to:
7.1.1. Provide information about personal data necessary for using the Website, placing an order, buying and selling goods remotely.
7.1.2. Update and supplement the provided information about personal data in the event of changes to such information by notifying the Operator at the email address — booking@azhursuzdal.ru or at the Operator’s address, indicating the data that is outdated and/or needs to be changed, deleted/destroyed and indicating the correct data.
7.1.3. Independently update his personal data in case of identifying inaccuracies by sending to the Operator’s address or notifying the Operator at the email address — booking@azhursuzdal.ru marked «Personal data update».
7.2. The Website Administration is obliged to:
7.2.1. Use the information received exclusively for the purposes specified in clause 4 of this Privacy Policy.
7.2.2. Ensure the storage of personal data in secrecy, not disclose without the prior written permission of the User and/or in cases established by the legislation of the Russian Federation, and also not sell, exchange, publish, or disclose by any other possible means the transferred personal data of the User, except for clauses 5.2., 5.9., 2.13.2. of this Regulation.
7.2.3. Take precautions to protect the confidentiality of the User’s personal data in accordance with the procedure commonly used to protect such information in existing business practice.
7.2.4. Block personal data relating to the relevant User from the moment of the User’s or his legal representative’s or the authorized body for the protection of the rights of personal data subjects’ application or request, for the period of verification, in case of detection of inaccurate personal data or unlawful actions.
8.1. The Website Administration that has not fulfilled its obligations shall be liable for losses incurred by the User in connection with the unlawful use of personal data, in accordance with the legislation of the Russian Federation, except for cases provided for in clauses 5.2. and 7.2., 5.9., 2.13.2. of this Regulation and provided that the fault of the Website Administration/Operator is proven.
8.2. In the event of loss or disclosure of Confidential Information, the Website Administration shall not be liable if such confidential information:
8.2.1. Became publicly available prior to its loss or disclosure.
8.2.2. Was received from a third party prior to its receipt by the Website Administration.
8.2.3. Was disclosed with the User’s consent.
9.1. Before filing a lawsuit in court regarding disputes arising from the relationship between the Website User and the Website Administration, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute).
9.2. The recipient of the claim shall, within 30 calendar days from the date of receipt of the claim, notify the claimant in writing of the results of the consideration of the claim.
9.3. If an agreement is not reached, the dispute will be referred for consideration to the judicial authority at the location of the Operator.
9.4. The current legislation of the Russian Federation applies to this Regulation and the relationship between the User and the Website Administration.
10.1. The Website Administration has the right to make changes to this Privacy Policy without the User’s consent.
10.2. The new Privacy Policy enters into force from the moment it is posted on the Website, unless otherwise provided by the new version of the Privacy Policy.
10.3. All suggestions or questions regarding this Privacy Policy should be sent to booking@azhursuzdal.ru.
10.4. The current Privacy Policy is posted on the Website — https://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