Privacy Policy

1. General Provisions

This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 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 Sole Trader Vasilyev Roman Viktorovich, OGRNIP 323784700332644, registered on 12 October 2023 (hereinafter — the Operator).

The Operator considers the observance of the rights and freedoms of individuals in the processing of their personal data, including the protection of the right to privacy, personal and family confidentiality, to be of utmost importance and a prerequisite for its activities.

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 websites https://sales.travel and https://инфотурист.рф.

2. Key Definitions Used in This Policy

• Automated processing of personal data — processing of personal data using computing equipment.
• Blocking of personal data — temporary suspension of personal data processing (except where processing is required for clarification of personal data).
• Website — the collection of graphic and informational materials, as well as computer programs and databases, that make them accessible on the internet at https://sales.travel and https://инфотурист.рф.
• Personal data information system — a set of personal data contained in databases and the information technologies and technical means that process them.
• Depersonalisation of personal data — actions as a result of which it is impossible to determine, without the use of additional information, whether personal data belong to a specific User.
• Processing of personal data — any action (operation) or set of actions performed with personal data, including collection, recording, systematisation, accumulation, storage, clarification, extraction, use, transfer, depersonalisation, blocking, deletion, and destruction of personal data.
• Operator — a state body, municipal body, legal entity or individual that independently or jointly with others organises the processing of personal data.
• Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://sales.travel.
• User — any visitor to the website https://sales.travel.
• Provision of personal data — actions aimed at disclosing personal data to a specific person or group of persons.
• Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons.
• Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.
• Destruction of personal data — any actions as a result of which personal data are permanently destroyed.

3. Principal Rights and Obligations of the Operator

The Operator is entitled to:

• Receive from the data subject accurate information and/or documents containing personal data.
• Where the data subject withdraws consent to the processing of personal data, continue processing without consent where grounds exist under the Personal Data Law.
• Independently determine the composition and list of measures necessary and sufficient to fulfil the obligations provided by the Personal Data Law.

The Operator is obliged to:

• Provide the data subject, upon request, with information regarding the processing of their personal data.
• Organise the processing of personal data in accordance with the procedure established by applicable Russian law.
• Respond to requests and enquiries from data subjects and their legal representatives.
• Notify the authorised body for the protection of the rights of data subjects, upon its request, of the necessary information within 30 days of receipt of the request.
• Publish or otherwise ensure unrestricted access to this Policy.
• Take legal, organisational, and technical measures to protect personal data against unauthorised or accidental access, destruction, modification, blocking, copying, or dissemination.
• Cease the transfer, processing, and destruction of personal data in the manner and cases provided for by the Personal Data Law.
• Fulfil other obligations provided for by the Personal Data Law.

4. Principal Rights and Obligations of Data Subjects

Data subjects are entitled to:

• Receive information regarding the processing of their personal data, except in cases provided for by federal laws.
• Require the Operator to clarify, block, or destroy their personal data if the data are incomplete, outdated, inaccurate, or unlawfully obtained.
• Impose a prior consent condition on the processing of personal data for the purpose of promoting goods, works, and services on the market.
• Withdraw consent to the processing of personal data.
• Appeal to the authorised body for the protection of the rights of data subjects or to the courts against unlawful acts or omissions of the Operator.
• Exercise other rights provided for by Russian legislation.

Data subjects are obliged to:

• Provide the Operator with accurate information about themselves.
• Notify the Operator of any updates (changes) to their personal data.

Persons who have provided the Operator with inaccurate information about themselves or information about another data subject without the latter's consent shall be liable in accordance with Russian legislation.

5. Personal Data the Operator May Process

• Email address.
• Telephone numbers.
• Taxpayer identification number, date of registration, and details of the certificate of registration with the tax authority.

The website also collects and processes anonymised data about visitors (including cookies) using internet analytics services (Yandex.Metrica, Google Analytics, and others).

The data listed above are referred to throughout this Policy collectively as Personal Data.

The Operator does not process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.

6. Principles of Personal Data Processing

• Personal data are processed on a lawful and fair basis.
• Processing is limited to achieving specific, predetermined, and lawful purposes. Processing incompatible with the purposes of collection is not permitted.
• Merging of databases containing personal data processed for incompatible purposes is not permitted.
• Only personal data that meet the purposes of their processing are subject to processing.
• The content and volume of personal data processed correspond to the stated processing purposes.
• The accuracy, sufficiency, and relevance of personal data in relation to the processing purposes are ensured during processing.
• Personal data are stored in a form that permits identification of the data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law or contract.

7. Purposes of Processing Personal Data

The purposes of processing the User's personal data are:

• Informing the User by sending emails.
• Entering into, performing, and terminating civil-law contracts.
• Providing the User with access to the services, information, and/or materials available on the website https://sales.travel.

The Operator is also entitled to send the User notifications about new products and services, special offers, and events. The User may unsubscribe from such communications at any time by sending an email to support@sales.travel with the subject "Unsubscribe from notifications".

Anonymised User data collected via internet analytics services are used to gather information about User behaviour on the website and to improve the quality of the website and its content.

8. Legal Grounds for Processing Personal Data

The legal grounds for the Operator's processing of personal data are:

• The constitutional (founding) documents of the Operator.
• Contracts entered into between the Operator and the data subject.
• Federal laws and other regulatory legal acts in the field of personal data protection.
• Consent of Users to the processing of their personal data, including data permitted for dissemination.

9. Conditions for Processing Personal Data

• The Operator processes the User's personal data only where the User has independently completed and/or submitted them via the dedicated forms on the website or sent them by email.
• The Operator processes anonymised data about the User where permitted by the User's browser settings (cookie storage and JavaScript are enabled).
• The data subject independently decides to provide their personal data and gives consent freely, of their own will, and in their own interest.
• Processing of personal data is carried out with the data subject's consent to such processing.
• Processing of personal data is necessary to achieve purposes stipulated by an international treaty or law.
• Processing of personal data is necessary for the performance of a contract to which the data subject is a party or beneficiary.
• Personal data that have been made publicly available by the data subject are processed.
• Personal data subject to publication or mandatory disclosure under federal law are processed.

10. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organisational, and technical measures required to fully comply with applicable personal data protection legislation.

• The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.
• The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of applicable law or where the data subject has consented to the transfer to a third party.
• Where inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notification to support@sales.travel with the subject "Personal Data Update".
• The period of personal data processing is determined by the achievement of the purposes for which the data were collected. The User may withdraw consent at any time by sending the Operator a notification to support@sales.travel with the subject "Withdrawal of Consent to Personal Data Processing".
• All information collected by third-party services, including payment systems and other service providers, is stored and processed by those parties in accordance with their own User Agreements and Privacy Policies.

11. List of Actions Performed by the Operator with Personal Data

• The Operator collects, records, systematises, accumulates, stores, clarifies (updates, modifies), extracts, uses, transfers (disseminates, provides, grants access to), depersonalises, blocks, deletes, and destroys personal data.
• The Operator carries out automated processing of personal data with or without the receipt and/or transmission of information received via information and telecommunications networks.

12. Cross-Border Transfer of Personal Data

• Prior to commencing a cross-border transfer of personal data, the Operator must verify that the foreign state to which the transfer is intended ensures adequate protection of the rights of personal data subjects.
• Cross-border transfer of personal data to foreign states that do not meet the above requirements may only be carried out with the written consent of the data subject and/or for the performance of a contract to which the data subject is a party.

13. Confidentiality of Personal Data

The Operator and any other persons who have obtained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the data subject, unless otherwise provided by federal law.

14. Final Provisions

• The User may obtain any clarification on matters relating to the processing of their personal data by contacting the Operator via email at support@sales.travel.
• Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
• The current version of the Policy is freely available on the internet at: https://sales.travel/privacy.