Policy on Personal Data Processing
1. General Provisions
This policy on personal data processing is formulated 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 defines the procedure for processing personal data and measures to ensure the security of personal data taken by Mikhail Yuryevich Pavlov (hereinafter referred to as the Operator).
1.1. The Operator sets compliance with the rights and freedoms of individuals as its paramount goal and condition for carrying out its activities in processing their personal data, including protecting 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 visitors to the website https://umbrella-hotel.com/.
2. Key Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology means.
2.2. Blocking of personal data — temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a combination of graphic and informational materials, as well as computer programs and databases providing their availability on the Internet at the network address https://umbrella-hotel.com/.
2.4. Personal data information system — a combination of personal data contained in databases and ensuring their processing by information technology and technical means.
2.5. Depersonalization of personal data — actions resulting in the inability to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who 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 subject to processing, 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://umbrella-hotel.com/.
2.9. Personal data permitted by the subject of personal data for distribution — personal data to which unlimited access is granted 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 provided by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://umbrella-hotel.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transferring personal data) or familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data by any other means.
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, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further recovery of the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
4.1. Personal data subjects have the right to:
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that corresponds to the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data storage is carried out in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract, one of the parties to which, the beneficiary or guarantor of which is the personal data subject. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. The purposes of personal data processing.
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary for the fulfillment of the purposes provided by an international treaty of the Russian Federation or by law, for the implementation of functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a judicial act, act of another authority or official that must be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the realization of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data is carried out for personal data that is publicly available, to which the personal data subject has provided access or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of 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 the 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. User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of applicable law or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator via email at the Operator's email address mail@umbrella-hotel.com with the subject "Update of personal data."
8.4. The processing period of personal data is determined by achieving the purposes for which personal data were collected, unless another period is provided by contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address mail@umbrella-hotel.com with the subject "Withdrawal 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 these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for dissemination, do not apply in cases of processing personal data in the public interest, as defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than necessary for the purposes of processing personal data, unless the storage period of personal data is established by federal law, contract, or by the personal data subject.
8.9. The termination of personal data processing may be conditioned by the achievement of the purposes of personal data processing, expiration of the consent period of the personal data subject, withdrawal of consent by the personal data subject, or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, updates (updates, modifies), extracts, uses, transfers (distributes, provides access), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with obtaining and/or transferring received information via information and telecommunication networks or without them.
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 personal data subjects of their intention to carry out the cross-border transfer of personal data (this notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of a 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 personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at mail@umbrella-hotel.com.
12.2. Any changes to the policy for processing personal data by the Operator will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at https://umbrella-hotel.com/en/policy
This policy on personal data processing is formulated 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 defines the procedure for processing personal data and measures to ensure the security of personal data taken by Mikhail Yuryevich Pavlov (hereinafter referred to as the Operator).
1.1. The Operator sets compliance with the rights and freedoms of individuals as its paramount goal and condition for carrying out its activities in processing their personal data, including protecting 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 visitors to the website https://umbrella-hotel.com/.
2. Key Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer technology means.
2.2. Blocking of personal data — temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website — a combination of graphic and informational materials, as well as computer programs and databases providing their availability on the Internet at the network address https://umbrella-hotel.com/.
2.4. Personal data information system — a combination of personal data contained in databases and ensuring their processing by information technology and technical means.
2.5. Depersonalization of personal data — actions resulting in the inability to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who 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 subject to processing, 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://umbrella-hotel.com/.
2.9. Personal data permitted by the subject of personal data for distribution — personal data to which unlimited access is granted 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 provided by the Personal Data Law (hereinafter referred to as personal data permitted for distribution).
2.10. User — any visitor to the website https://umbrella-hotel.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transferring personal data) or familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication networks, or providing access to personal data by any other means.
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, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further recovery of the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
- receive from the subject of personal data accurate information and/or documents containing personal data;
- in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as the submission of an application demanding the cessation of processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data 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 for by the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.
- provide the subject of personal data, upon 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 inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
- provide the necessary information to the authorized body for the protection of the rights of subjects of personal data upon request of this body within 10 days from the date of receiving such request;
- publish or otherwise provide 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, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
- terminate the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
- fulfill other obligations provided for by the Personal Data Law.
4.1. Personal data subjects have the right to:
- receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating 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 are established by the Personal Data Law;
- demand from the operator clarification of their personal data, their blocking or destruction if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take legal measures provided for by law to protect their rights;
- require 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, as well as submit a request to cease processing personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
- exercise other rights provided for by Russian legislation.
- provide the Operator with accurate information about themselves;
- inform the Operator of the clarification (updating, changing) of their personal data.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data that corresponds to the purposes of their processing are subject to processing.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data storage is carried out in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, a contract, one of the parties to which, the beneficiary or guarantor of which is the personal data subject. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
6. The purposes of personal data processing.
- The purpose of processing: Informing the User through sending emails.
- Personal data: Last name, first name, patronymic (if applicable), email address, phone numbers.
- Legal grounds: Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006, No. 149-FZ.
- Types of personal data processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary for the fulfillment of the purposes provided by an international treaty of the Russian Federation or by law, for the implementation of functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
7.3. Processing of personal data is necessary for the administration of justice, enforcement of a judicial act, act of another authority or official that must be enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract initiated by the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for the realization of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data is carried out for personal data that is publicly available, to which the personal data subject has provided access or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of 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 the 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. User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of applicable law or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator via email at the Operator's email address mail@umbrella-hotel.com with the subject "Update of personal data."
8.4. The processing period of personal data is determined by achieving the purposes for which personal data were collected, unless another period is provided by contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address mail@umbrella-hotel.com with the subject "Withdrawal 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 these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for dissemination, do not apply in cases of processing personal data in the public interest, as defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than necessary for the purposes of processing personal data, unless the storage period of personal data is established by federal law, contract, or by the personal data subject.
8.9. The termination of personal data processing may be conditioned by the achievement of the purposes of personal data processing, expiration of the consent period of the personal data subject, withdrawal of consent by the personal data subject, or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator collects, records, systematizes, accumulates, stores, updates (updates, modifies), extracts, uses, transfers (distributes, provides access), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with obtaining and/or transferring received information via information and telecommunication networks or without them.
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 personal data subjects of their intention to carry out the cross-border transfer of personal data (this notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of a 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 personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can receive any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at mail@umbrella-hotel.com.
12.2. Any changes to the policy for processing personal data by the Operator will be reflected in this document. The policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at https://umbrella-hotel.com/en/policy