Personal Data Processing Policy
1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ “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 taken by TREZOR Limited Liability Company (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of an individual and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://idera.revtail.ru.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data is the processing of personal data using computer technology.
2.2. Blocking of personal data is a temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website is a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://idera.revtail.ru.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another subject of personal data.
2.6. Personal data processing — any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such 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 government agency, municipal agency, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly related to a specific or determinable User of the website https://idera.revtail.ru.
2.9. Personal data permitted for distribution by the subject of personal data — personal data, access to which by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://idera.revtail.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 familiarizing an unlimited number of persons with personal data, including disclosure of personal data in the media, posting in information and telecommunications 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 a government body of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are irrevocably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of tangible media of personal data.
3. Basic rights and responsibilities of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— if the personal data subject revokes consent to the processing of personal data, as well as sends an appeal with a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The operator is obliged to:
— provide the personal data subject, at his request, with information regarding the processing of his personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
— notify the authorized body for the protection of the rights of personal data subjects, at the request of this body, of the necessary information within 10 days from the date of receipt of such 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 to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;
— fulfill other obligations stipulated by the Law on Personal Data.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right:
— receive information regarding the processing of their personal data, with the exception of cases stipulated by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
— demand that the operator clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also take measures provided by law to protect his rights;
— to revoke consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Operator when processing his personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable data about themselves;
— notify the Operator about clarification (update, change) of their personal data.
4.3. Persons who have transferred to the Operator false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data shall be processed on a lawful and fair basis.
5.2. Personal data shall be limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data shall not be permitted.
5.3. Combining databases containing personal data processed for purposes incompatible with each other shall not be permitted.
5.4. Only personal data that meet the purposes of their processing shall be processed.
5.5. The content and volume of personal data processed shall correspond to the stated purposes of processing. Excessive amounts of personal data processed in relation to the stated purposes of their processing shall not be permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency and, where necessary, relevance in relation to the purposes of processing personal data shall be ensured. The operator shall take the necessary measures and/or ensure that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the subject of personal data to be identified, for no longer than is required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or in the event of loss of need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of personal data processing
| Purpose of processing | providing the subject with information related to the provision of services or sale of goods through various communication channels (mail, SMS messages, email, phone call) |
| Personal data | last name, first name, patronymic contact email address contact phone number (home, mobile) other information provided by the subject of personal data |
| Legal basis | Federal Law “On Information, Information Technologies and Information Protection” dated 27.07.2006 N 149-FZ |
| Types of personal data processing | Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data Sending information letters to the email address |
7. Terms of personal data processing
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. Personal data shall be processed to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to exercise the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.
7.3. Personal data shall be processed to administer justice, to enforce a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data shall be processed to perform an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as to conclude an agreement on the initiative of the personal data subject or an agreement under which the personal 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 goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. The processing of personal data is carried out, access to which is provided to an unlimited number of persons by the personal data subject or at his request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data is subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for collecting, storing, transferring 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 current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing 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 implementation of current legislation or in the event that the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In the event that inaccuracies are detected in personal data, the User can update them independently by sending a notification to the Operator to the Operator’s email address hotel@idera.revtail.ru with the subject line “Updating personal data”.
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the agreement or current legislation.
The User may at any time revoke their consent to the processing of personal data by sending a notification to the Operator via e-mail to the Operator’s e-mail address hotel@idera.revtail.ru with the subject line “Revocation of consent to the processing of 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 the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. Subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, shall not apply in cases of processing personal data in the state, public and other public interests determined by the legislation of the Russian Federation.
8.7. The operator ensures the confidentiality of personal data when processing personal data.
8.8. The operator stores personal data in a form that allows identifying the subject of personal data, for no longer than required for the purposes of processing personal data, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the subject of personal data, revocation of consent by the subject of personal data or a requirement to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.
9. List of actions performed by the Operator with the received personal data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.
10. Cross-border transfer of personal data
10.1. Before starting 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 personal data subjects of its intention to carry out the cross-border transfer 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 is obliged to obtain the relevant information from the authorities of a foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Cookies and automatic logging.
11.1 Cookies are one of the technologies that we use to automatically collect information and improve the quality of content. A cookie is a small text file placed on a user’s computer to analyze their user activity. The information collected using cookies cannot identify you, but it can help us improve the performance of our site.
11.2 Just like most other information resources of organizations, our web servers and security systems from time to time store some temporary technical data in their log files.
12. Using web analytics services:
12.1 The website https://idera.revtail.ru uses the Yandex.Metrica web analytics service provided by YANDEX Limited Liability Company (hereinafter referred to as Yandex).
12.2 Yandex.Metrica uses cookie technology. (Yandex.Metrica does not collect identifying information). According to Yandex.Metrica’s privacy policy (https://yandex.ru/support/metrica/general/confidential-data.html), in order to preserve the confidentiality of personal data, the terms of use of the Yandex.Metrica service prohibit the transfer of identifying information to Metrica.
12.3 Information about the Visitor’s use of this site, collected using cookies, will be transferred to Yandex and stored on the Yandex server. Yandex will process this information in the interests of the site owner, in particular to evaluate the Visitor’s use of the site, compiling reports on activity on the site. Yandex processes this information in the manner set out in the Terms of Use of the Yandex.Metrica service.
12.4 The Visitor can refuse the use of cookies by selecting the appropriate settings in the browser. The User can also use the tool — https://yandex.ru/support/metrika/general/opt-out.html. However, this may affect the operation of some functions of the site. By using this site, the Visitor agrees to the processing of data about the Visitor by Yandex in the manner and for the purposes specified above.
12.5 Other tools for tracking traffic statistics and integration into social networks that are used or may be used on the site: other Yandex services; Vkontakte pixel, Google.Analytics and others.
13. Confidentiality of personal data
13.1 The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
13.2 The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.
14. Final provisions
14.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail hotel@idera.revtail.ru.
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://idera.revtail.ru/privacy-policy/.
