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 individual entrepreneur Anatoly Yuryevich Solonko (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man 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://so-spb.com.

 

2. Basic concepts used in the Policy

2.1. A website is a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at a network address https://so-spb.com.

2.2. Processing of personal data is 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), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.3. Operator -IP Solonko Anatoliy Yuryevich, OGRNIP 324470400088056, INN 470517772665.

2.4. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://so-spb.com.

2.5. User – any visitor to the website https://so-spb.com.

2.6. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.

 

3. Basic rights and obligations of the Operator

3.1. The operator has the right:

— receive reliable information and/or documents containing personal data from the subject of personal data;

— in the event of the personal data subject’s withdrawal of consent to the processing of personal data, as well as the sending of an application 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 subject of personal data, at his request, with information concerning the processing of his personal data;

— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

— respond to requests and inquiries from 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 provide unrestricted 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. Subjects of personal data have the right to:

— receive information regarding the processing of his personal data, except for cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except for 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 Law on Personal Data;

— to put forward the condition of prior consent when processing personal data for the

— to revoke consent to the processing of personal data, as well as to send a request to stop the processing of personal data;

— 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 information about yourself;

— inform the Operator about clarification (update, change) of your personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.

 

5. Principles of personal data processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.

5.3. It is not permitted to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.

5.4. Only personal data that meets the purposes of their processing are subject to processing.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive amounts of personal data processed in relation to the stated purposes of their processing are not permitted.

5.6. When processing personal data, the accuracy of the personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing the personal data are ensured. The operator takes the necessary measures and/or ensures their adoption 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 achieving the purposes of processing 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:

  1. Conclusion and execution of lease agreements;
  2. Informing the User by sending e-mails (booking confirmation/booking cancellation);
  3. Communication with the User regarding booking, check-in, etc.;
  4. Informing the User by sending emails (with news, special offers, etc.)

 

Personal data:

  • last name, first name, patronymic
  • email address
  • phone numbers
  • year, month, date and place of birth
  • details of the identity document
  • address of actual place of residence and registration at the place of residence and/or place of stay
  • technical data (IP address, browser type, access time, etc.)

 

Legal basis:

  • agreements concluded between the operator and the subject of personal data;
  • federal laws, other regulatory legal acts in the field of personal data protection;
  • I agree I User to her to the processing of their personal data.

 

Types of personal data processing:

Collection, recording, systematization, accumulation, storage, clarification (update), change, use, transmission pred (installation, access),destruction and depersonalization of personal data;

Sending informational letters to an email address.

 

7. Terms of personal data processing

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.

7.2. The processing of personal data is necessary 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. The processing of personal data is necessary for the administration of justice, the execution of 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. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of 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 for the exercise of the rights and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

7.6. The processing of personal data is carried out, access to which by an unlimited number of persons is provided by the subject of the personal data 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 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 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 of detection of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator by email to the Operator’s address so-spb-apart@yandex.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 applicable legislation.

The User may at any time revoke their consent to the processing of personal data by sending the Operator a notification via e-mail to the Operator’s e-mail address so-spb-apart@yandex.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 said persons (Operators) in accordance with their User Agreement and Privacy Policy. Subject of personal data and/or with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. 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 of personal data in state, public and other public interests determined by the legislation of the Russian Federation.

8.7. When processing personal data, the operator ensures the confidentiality of personal data.

8.8. The operator shall store personal data in a form that allows the identification of the subject of personal data for no longer than is required by the purposes of processing the 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.

8.9. The condition for termination of the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or the requirement 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 the received personal data

9.1. The operator collects, records, systematizes, accumulates, stores, clarification (update, change), use, transfer (provision, access), depersonalization, and destruction of personal data.

9.2. The operator carries out both automated and non-automated processing of personal data.

 

10. Confidentiality of personal data

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 subject of the personal data, unless otherwise provided by federal law.

 

11. Final Provisions

11.1. The User may obtain any clarifications on issues of interest concerning the processing of his personal data by contacting the Operator via e-mail so-spb-apart@yandex.ru.

11.2. 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.

11.3. The current version of the Policy is freely available on the Internet at https://so-spb.com/en/privacy/.

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