PRIVACY POLICY


Policy on the Processing of Personal Data
1.General Provisions
This policy on the processing of personal data is developed 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 determines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Ilchishin Petr Georgievich (hereinafter referred to as the Operator).
1.1. The Operator's primary goal and condition for carrying out its activities is to respect the rights and freedoms of an individual and a citizen when processing their personal data, including the protection of the right to privacy, personal, and family secrets.
1.2. This Operator’s policy on 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://susanintours.com
2.Key Concepts Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing technology.
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 set of graphic and informational materials, as well as software for computers and databases that ensure their availability on the Internet at the network address https://susanintours.com.
2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. De-identification of personal data – actions that make it impossible to determine without the use of additional information the belonging of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data – any action (operation) or a combination of actions (operations) performed using automation tools or without such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, destruction of personal data.
2.7. Operator – a government 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, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://susanintours.com.
2.9. Personal data permitted by the subject of personal data for dissemination — personal data to which access to an unlimited number of persons has been granted by the subject of personal data by giving consent to process personal data authorized by the subject of personal data for dissemination in accordance with the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User — any visitor to the website https://susanintours.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. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at providing access to personal data to an unlimited number of persons, including the public disclosure of personal data in the media, posting on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or the destruction of physical carriers of personal data.
3.Basic Rights and Obligations of the Operator
3.1. The Operator has the right:
— to receive accurate information and/or documents containing personal data from the subject of personal data;
— in case the subject of personal data withdraws consent for processing personal data, as well as in the case of submitting a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data when there are grounds specified in the Personal Data Law;
— to 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 the regulations 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 subject of personal data, at their request, with information regarding the processing of their personal data;
— to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— to respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— to notify the authorized body for the protection of the rights of subjects of personal data, at the request of this body, of necessary information within 10 days from the date of receipt of such a request;
— to publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data.
— to take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data;
— to cease the transfer (distribution, provision, access) of personal data, to stop processing, and to destroy personal data in the manner and cases provided for by the Law on Personal Data;
— to perform other obligations provided for by the Law on Personal Data.
4. Main Rights and Obligations of Personal Data Subjects
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 shall be provided to the personal data subject by the Operator in an accessible form, and it shall not contain personal data pertaining to other personal data subjects, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
— to require the Operator to correct their personal data, block, or destroy it in cases where the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
— to impose a condition of prior consent when processing personal data for the purposes of promoting goods, works, and services;
— to withdraw consent to the processing of personal data, as well as to submit a request for the cessation of the processing of personal data;
— to appeal to the authorized body for the protection of the rights of personal data subjects or to seek judicial remedy against unlawful actions or inactions of the Operator in processing their personal data;
— to 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;
— notify the Operator of any clarifications (updates, changes) to their personal data.
4.3. Individuals who provide the Operator with false information about themselves, or information about another personal data subject without the latter's consent, bear responsibility 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 lawful purposes. The 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, the processing of which is carried out for incompatible purposes, is not allowed.
5.4. Only personal data that meets the purposes of their processing shall be subjected to processing.
5.5. The contents and scope of the processed personal data correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, its sufficiency, and, when necessary, its relevance to the purposes of processing personal data are ensured. The operator takes necessary measures and/or ensures their implementation for the removal or clarification of incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows for the identification of the subject of personal data, no longer than is required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, agreement, of which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or de-identified upon achieving the purposes of processing or in the event of losing the necessity to achieve these purposes, unless otherwise provided by federal law.
6.Purposes of processing personal data
The purpose of processing is to inform the User by sending electronic letters.
Legal basis - Federal Law "On Information, Information Technologies, and Information Protection" dated 27.07.2006 N 149-FZ.
Types of processing personal data - Transfer of personal data.
7.Conditions of processing personal data
7.1. The processing of personal data is carried out with the consent of the subject of personal data for processing their personal data.
7.2. Processing of personal data is necessary to achieve the purposes stipulated by the international treaty of the Russian Federation or by law, to perform functions, authorities, and obligations imposed on the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary to administer justice, enforce a court act, an act of another body, or a public official, subject to execution 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, of which the subject of personal data is a party or a beneficiary or guarantor, as well as for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data 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 to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Processing of personal data is carried out, the access of an unlimited number of persons to which has been granted by the subject of personal data or at their request (hereinafter referred to as 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 collection, storage, transmission, and other types of processing of personal data
The safety 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 exclude unauthorized access to personal data.
8.2. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement 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 case of identifying inaccuracies in the personal data, the User may update it independently by sending a notification to the Operator at the email address susanintours@gmail.com with the subject "Updating Personal Data".
8.4. The duration of processing personal data is determined by the achievement of the purposes for which the personal data was collected unless a different term is provided by a contract or applicable law.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email to the email address susanintours@gmail.com with the subject "Revocation of Consent to Process Personal Data".
8.5. All information collected by third-party services, including payment systems, communication means, 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 mentioned documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
8.6. The prohibitions 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 accessing) personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows for identifying the personal data subject for no longer than is required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract of which the personal data subject is a party or beneficiary, or guarantor.
8.9. The termination of processing personal data may result from the achievement of the purposes of processing personal data, expiration of the personal data subject’s consent, revocation of consent by the personal data subject, or a request to cease processing personal data, as well as the detection of unlawful processing of personal data.
9. List of actions performed by the Operator with the received personal data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information through information and telecommunication networks or without such.
10. Cross-border transfer of personal data
10.1. Before commencing activities for 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 its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above-mentioned notification, the Operator is obliged to obtain the relevant information from foreign authorities, foreign individuals, and 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 and not to distribute it without the consent of the subject of personal data, unless otherwise provided by federal law.
12.Final Provisions
12.1. The User can obtain any clarifications on issues related to the processing of their personal data by contacting the Operator via email at susanintours@gmail.com.
12.2. Any changes to the Operator's personal data processing policy 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 in English is freely available on the Internet at https://susanintours.com/privacy/en