Personal data processing policy

Privacy policy
1. General Provisions

This Personal Data Processing Policy is prepared in accordance with Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, and outlines the procedure for processing personal data and measures to protect the security of personal data undertaken by Olga N. Krasilnikova (hereinafter, the 'Operator').


1.1. The Operator shall treat the upholding of human rights and freedoms in the processing of personal data, including the protection of privacy, personal and family secrets, as its priority and a precondition for doing business.


1.2. This Personal Data Processing Policy (hereinafter, the 'Policy') shall apply to all information which the Operator mayobtain about visitors to the http://hotel-sretenskaya.ru website.

2. Key Terms used in the Policy

2.1. 'Automated personal data processing' means personal data processing using computer equipment;


2.2. 'Personal data blocking' means temporary suspension of personal data processing (unless such processing is necessary to clarify personal data);



2.3. 'Website' means a totality of graphic and informational materials, along with computer programmes and databases, which ensure their accessibility on the internet via the IP address http://hotel- sretenskaya.ru/;


2.4. 'Personal data information system' means a collection of personal data stored in databases, and the information technologies and technical means which facilitate their processing;


2.5. 'Anonymisation of personal data' means actions that make it impossible to identify that personal data belongs to a specific User or any other personal data subject without additional information;


2.6. 'Personal data processing' means any action/operation or series actions/operations involving personal data performed with or without automation tools, including collection, recording, systematisation, accumulation, storage, refinement (updating, modification), extraction, usage, transmission (distribution, provision, access), anonymisation, blocking, deletion and destruction of personal data;



2.7. 'Operator' means a state body, a municipal authority, a legal entity or an individual who independently or jointly with other persons organizes the processing of personal data and/or processes them, as well as determines the purposes of processing personal data, the composition of personal data to be processed , and actions/operations related to personal data;

2.8.. 'Personal data' means any information which directly or indirectly pertains to a specific or identifiable User of the http://hotel-sretenskaya.ru/ website;



2.9. 'User' means any visitor to the http://hotel-sretenskaya.ru/ website;


2.10. 'Personal data disclosure' means actions intended to disclose personal data to a particular person or particular range of persons;



2.11. 'Distribution of personal data' means any actions intended to disclose personal data to an unspecified group of people (transfer of personal data) or to familiarise an unlimited number of people with personal data, including publicising personal data in the media, posting on information and telecommunication networks, or providing access to personal data in any other manner;



2.12. 'Cross-border transfer of personal data' means a transfer of personal data to the territory of a foreign country to an authority of the foreign country, a foreign individual or foreign legal entity;


2.13. 'Personal data destruction' means any actions which result in the irreversible destruction of personal data, making it impossible to recover the content of personal data in the personal data information system, and/or in the destruction of the tangible media containing personal data.

3. The Operator may process the following personal data of the User

3.1. Telephone number, e-mail address, full name;


3.2. The website shall also gather and process anonymised data about visitors (including cookies) through the use of internet statistics services (such as Yandex Metrics, Google Analytics, etc.).

3.3. The above-listed data is hereinafter collectively referred to as 'Personal Data'.
4. Goals of personal data processing
4.1. The goal of processing the User's personal data shall be to provide information via telephone with the aim of rendering service.

4.2. The Operator also reserves the right to send notifications to the User about new products and services, special offers and various events. The User may always refuse to receive informational messages by sending an e-mail to the Operator at fin@hotel-sretenskaya.ru with the subject line 'Unsubscribe from notifications about new products, services, and special offers'.

4.3. Anonymised data of Users collected via internet statistics services shall be used to gather information about User activity on the website and to enhance the quality of and content of the website.
5. Legal Grounds for Processing Personal Data
5.1. The Operator shall process the User's personal data only if it is completed and/or sent by the User in an unassisted manner through specific forms on the website at fin@hotel-sretenskaya.ru. By completing the relevant forms and/or sending their personal data to the Operator, the User consents to this Policy.

5.2. The Operator shall process anonymised User data if it is permitted in the User's browser settings (including the saving of cookies and the use of JavaScript technology).
6. Procedure for collecting, storing, transmitting, and other forms of personal data processing
he Operator shall ensure the security of personal data by implementing legal, organisational and technical measures to fully comply with the requirements of the personal data protection laws currently in force.

6.1. The Operator shall safeguard personal data and take all necessary steps to prevent unauthorised access to the same.

6.2. The User's personal data shall never, under no circumstances, be disclosed to third parties, except when necessitated by compliance with the laws currently in force.

6.3. If any inaccuracies in personal data are identified, the User may update them by sending an e-mail to the Operator at fin@hotel-sretenskaya.ru with the subject line 'Personal Data Update'.

6.4. Personal data processing shall be of indefinite duration. The User may revoke their consent to personal data processing at any time by sending an e-mail to the Operator at fin@hotel-sretenskaya.ru with the subject line 'Withdrawal of Consent to Personal Data Processing'.
7. Cross-Border Transfer of Personal Data
7.1. Before initiating a cross-border transfer of personal data, the Operator shall be required to ensure that the foreign country to which the data is being transferred provides adequate protection for the rights of personal data subjects.

7.2. Cross-border transfer of personal data to foreign countries which do not meet the aforesaid requirements may only occur if the personal data subject gives consent in writing or if it is required for the performance of a contract to which the personal data subject is a party
8. Final Provisions
8.1. The User may get any clarifications on any questions related to their personal data processing by contacting the Operator via e-mail at fin@hotel-sretenskaya.ru.

8.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy shall be of indefinite duration until a new version replaces it.

8.3. The latest version of the Policy is freely accessible online at http://hotel-sretenskaya.ru/privacy.