1. General Provisions

This Personal Data Processing Policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter — the Personal Data Law), and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by LLC “POLE” (hereinafter — the Operator).

1.1. The Operator considers compliance with human and civil rights and freedoms during the processing of personal data, including the protection of the right to privacy and personal and family confidentiality, to be its most important objective and a mandatory condition of its activities.

1.2. This Policy of the Operator regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://polehotel.ru/

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at https://polehotel.ru/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of determining, without the use of additional information, the ownership of personal data by a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual who independently or jointly with others organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed on personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://polehotel.ru/.
2.9. Personal data permitted by the personal data subject for distribution — personal data to which access by an unlimited number of persons is granted by the personal data subject by giving consent to the processing of personal data permitted for distribution in accordance with the procedure provided for by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://polehotel.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. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including publication in mass media, placement in information and telecommunications 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, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or destruction of physical media containing personal data.

3. Main Rights and Obligations 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;
— in the event that the personal data subject withdraws consent to the processing of personal data, as well as submits a request to terminate the processing of personal data, continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:
— provide the personal data subject, at their request, with information relating to the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, at its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
— terminate the transfer (dissemination, provision, access) of personal data, terminate 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. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
— receive information relating to the processing of their personal data, except in cases provided for by federal laws. Such information is provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are lawful grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights;
— set a condition of prior consent for the processing of personal data for the purposes of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data, as well as submit a request to terminate the processing of personal data;
— appeal unlawful actions or inaction of the Operator in the processing of their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator of any clarification (updating or change) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another personal data subject without the consent of that subject, shall bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data are processed on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The merging of databases containing personal data processed for purposes that are incompatible with each other is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, their accuracy, sufficiency, and, where necessary, relevance in relation to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures that such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or when the need to achieve those purposes no longer exists, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: informing the User by sending emails
Personal data: last name, first name, patronymic, email address, phone numbers
Legal basis: the Operator’s statutory (founding) documents
Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data

7. Conditions for Personal Data Processing

7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes stipulated by an international treaty of the Russian Federation or by law, and to carry out the functions, powers, and obligations assigned to the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, or an act of another authority or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing 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 at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data is carried out where access to such data is granted to an unlimited number of persons by the personal data subject or at their request (hereinafter — publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing

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 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 access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable legislation or where the personal data subject 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. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address INFO@POLEHOTEL.RU with the subject line “Personal Data Update.”
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or applicable legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator by email to INFO@POLEHOTEL.RU with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject independently familiarizes themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for granting access) of personal data permitted for distribution, do not apply in cases where personal data are processed in state, public, or other public interests defined 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 stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for termination of personal data processing may include the achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a request to terminate personal data processing, or identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunications networks or without such networks.

10. Cross-Border Transfer of Personal Data

10.1. Prior to commencing activities involving the cross-border transfer of personal data, the Operator is required to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer (this notification is submitted separately from the notification of intent to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator is required to 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 or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at INFO@POLEHOTEL.RU.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://polehotel.ru/privacy