Policy regarding the personal data processing of the Vozdushnaya Gavan Hotel official website users (JSC “International Airport Irkutsk”)
1. GENERAL TERMS
1.1 Joint-stock company “International Airport Irkutsk” sets the observance of the rights and freedoms of citizens as the main course of its activities’ implementation, respects the confidentiality of Users of the Website and strictly complies with the data protection laws.
1.3 Basic terms used in the Policy:
• website – a set of soft computers hardware providing data publishing on the Internet. The Website is available at https://hotel.iktport.ru/;
• user – any visitor to the website https://hotel.iktport.ru/;
• operator – JSC “International Airport Irkutsk” carrying out the personal data processing as well as determining the purposes of personal data processing, the scope of personal data to be processed, operations performed with personal data;
• personal data – any information related to a directly or indirectly identified User of the Website;
• personal data processing – any action (operation) or a set of actions (operations) performed on the personal data with or without using of automation tools. Personal data processing includes the collection, recording, systematization, accumulation, storage, clarification (updating, alteration), extraction, use, transfers (dissemination, provision, making available and accessible), depersonalisation, blocking, erasure, destruction of personal data;
• data depersonalization – actions which cause impossibility to determine the ownership of personal data to a particular User or other personal data subject without the use of additional information;
• personal data dissemination – any actions aimed at disclosure of personal data to an unlimited number of persons;
• personal data provision – any actions aimed at disclosure of personal data to a certain person or to a certain number of persons;
• destruction of personal data – any actions aimed at deleting personal data irretrievably and without any possibility of its further recovering in the information system, or any actions aimed at destroying physical storage media with personal data.
1.4 When using the Website, the User shall consent to his/her personal data processing. The User shall consent to his/her personal data being processed by the Operator in compliance with Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006 as amended at the time of processing of this personal data.
1.5 The consent to personal data processing provided on the Website shall be valid until the purposes of personal data processing set forth herein are achieved.
1.6 The Operator may process the following personal data: the User’s full name, telephone number, e-mail address of the User.
1.7 The Operator may also collect and process depersonalized data on Users by means of web analytics services.
2. PURPOSES OF COLLECTION AND PROCESSING PERSONAL DATA
2.1 Collection and processing of the User’s personal data are performed for the purposes of:
• providing access to Operator’s services;
• clarification of online-reservation details;
• confirming hotel reservation;
• carrying out surveys for the purposes of improvement quality of provided services;
• processing User’s requests, inquiries and claims; and for further responding and/or in order to get in touch with the User.
2.2 Collection and processing of analytical information based on depersonalized User’s data are carrying out for the purpose of statistical and other studies.
3. LEGAL BASES FOR PROCESSING OF THE PERSONAL DATA
3.1 Processing of the User’s personal data is carried out by the Operator only if that personal data was sent by the User through the Operator’s Website forms.
3.2 Depersonalized data processing is carrying out by the Operator only in case it is allowed in User’s browser settings.
3.3 The Operator shall comply with the principles of personal data processing as provided for by the applicable laws.
3.4 The legal basis for personal data processing shall be the federal laws and regulations in compliance with and according to which the Operator processes personal data, including:
• the Constitution of the Russian Federation;
• the Civil Code of the Russian Federation;
• Federal Law No.152-FZ “On Personal Data” dated July 27, 2006;
• other laws and regulations governing the relations related to the Operator’s activity.
3.5 The Operator processes personal data in accordance with laws and regulations outlined in paragraph 3.4 herein, which shall be valid in the revisions being effective at the time of personal data processing.
3.6 The legal basis for personal data processing shall also be:
• the Operator’s charter;
• contracts concluded by the Operator and personal data subjects;
• consent of personal data subjects to their personal data processing;
• contracts concluded by the Operator and other Operators of personal data.
4. CATEGORIES OF PERSONAL DATA FOR PROCESSING
4.1 The content and scope of personal data being processed comply with the stated purposes.
4.2 The Operator shall not process and does not intend to process special categories of personal data concerning race, ethnicity, political opinions, religious or philosophical beliefs, or personal life.
4.3The categories of personal data subjects include:
• clients and partners of the Operator (individuals);
• employees / representatives of the Operator’s clients and partners (legal entities).
4.4 The categories of personal data (information), for which the User provides his/her consent for processing, shall include: the User’s full name; telephone number; e-mail address; IP addresses with which the User connected; data on the location of User’s device obtained during the Website use.
5. PROCEDURE FOR AND TERMS OF COLLECTING AND PROCESSING PERSONAL DATA
5.1 The Operator may process personal data only for the purposes provided for this Policy and undertake not to disclose (transfer, share) User’s personal data to third parties, unless otherwise specified herein or in the applicable laws.
5.2 The Operator shall ensure personal data is kept secure and shall take all reasonable steps to prevent unauthorized access.
5.3 The Operator has the right to transfer User’s personal data to the authorized state authorities of the Russian Federation on statutory grounds.
6. STORAGE AND DESTRUCTION OF PERSONAL DATA
6.1 Terms for ceasing processing the personal data are the following cases: the purposes of processing personal data have been achieved; the data subject has withdrawn his/her consent to the processing of personal data; illegal processing of personal data is detected.
6.2 Personal data shall be stored as long as it is required for the purposes of processing personal data unless a different period of personal data storage is set by the applicable laws.
6.3 The personal data processed shall be destroyed or depersonalized upon achieving the processing purposes or if it is no longer required to achieve such objectives, unless otherwise provided for by the applicable laws.
6.4 Personal data shall be processed by taking the corresponding technical and organizational actions that are strictly necessary for the purpose of processing the personal data.
6.5 Upon the personal data subject or his/her representative request, the Operator shall confirm whether his/her personal data is processed.
7. AMENDMENTS TO THE POLICY
7.1 In case of any changes or amendments to this Policy, the Operator posts these changes on the Website to notify the User thereof.
7.2 In using Operator’s Website, the User shall confirm that they have read, understood and comply with all amendments hereto upon their publication.
7.3 Further use of the Website (including by simple access and browsing) shall mean that the User accepts and agrees with any amendments to this Policy.
8. FINAL PROVISIONS
8.2 The User may withdraw his/her consent with this Policy at any time. In some cases, the User’s withdrawal may prevent the person from receiving some of the Operator’s services. Withdrawing consent shall not affect the legality of the Operator’s processing of User’s personal data until the corresponding withdrawal is received.
8.4 Upon receiving the withdrawal of consent to the personal data processing, the Operator shall cease processing the User’s personal data within thirty (30) calendar days at the latest.