Policy Regarding the Processing of Personal Data
1. General ProvisionsThis policy on the processing of personal data has been prepared 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 defines the procedure for processing personal data and the measures taken by Ludmila Tours (hereinafter referred to as the Operator) to ensure the security of personal data.
1.1. The Operator sets as its most important goal and condition for its activities the observance of the rights and freedoms of man and citizen in the processing of their personal data, including the protection of the rights to privacy of private life, 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 obtain about visitors to the website https://ludmila-tours.com/.
2. Key Terms Used in the Policy2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary suspension of processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a combination of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet under the network address https://ludmila-tours.com/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine without the use of additional information the affiliation of personal data with a specific User or other subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation tools or without using 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.
2.7. Operator — a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, 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://ludmila-tours.com/.
2.9. Personal data permitted by the subject of personal data for dissemination — personal data to which an unlimited circle of persons has been granted access by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://ludmila-tours.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 circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including publication of personal data in the 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 the authority of a foreign state, foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data is irreversibly destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Main Rights and Obligations of the Operator3.1. The Operator has the right:
- to receive from the subject of personal data reliable information and/or documents containing personal data;
- in case of withdrawal by the subject of personal data of consent to the processing of personal data, as well as the submission of a request for termination of the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if 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 the duties provided for by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
- to provide the subject of personal data, upon request, with information regarding the processing of his personal data;
- to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- to respond to requests and inquiries 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, upon request of this body, of the necessary information within 10 days from the date of receipt of such request;
- to publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
- to take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
- to cease the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- to fulfill other duties provided for by the Personal Data Law.
- to receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in 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 Personal Data Law;
- to demand from the operator the clarification of his personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, as well as to take the measures provided by law to protect their rights;
- to set the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
- to appeal to the authorized body for the protection of the rights of subjects of personal data or in a judicial procedure the unlawful actions or inaction of the Operator when processing their personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.
- to provide the Operator with accurate data about themselves;
- to notify the Operator of the clarification (update, modification) of their personal data.
5. Principles of Processing Personal Data5.1. Processing of personal data is carried out on a legal and fair basis.
5.2. Processing of personal data is limited to achieving specific, predefined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The excess of the processed personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and in necessary cases relevance to the purposes of processing personal data is ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, contract, a party to which, beneficiary or guarantor under which is the subject of personal data. Processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of necessity in achieving these purposes, unless otherwise provided by federal law.
Purpose of Processing | Personal Data | Legal Basis | Types of Processing |
Informing the User by sending emails | Surname, first name, patronymic; email address; phone numbers | Charter (constituent) documents of the Operator; contracts concluded between the Operator and the subject of personal data | Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data; Sending informational emails to the email address; Analytics using Yandex.Metrica |
7. Conditions for Processing Personal Data7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to exercise the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or 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 execution of a contract to which the subject of personal data is a party or beneficiary or guarantor under it, as well as for concluding a contract on 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 to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. Processing of personal data to which an unlimited circle of persons has been granted access by the subject of personal data or at their request (hereinafter — publicly available personal data) is carried out.
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, Transfer and Other Types of Personal Data ProcessingThe 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 exclude access to personal data by unauthorized persons.
8.2. User's personal data will never be transferred to third parties under any circumstances, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@ludmila-tours.com with the note "Update of personal data".
8.4. The term of processing personal data is determined by the achievement of the purposes for which the personal data was collected, if another term is not provided for by the contract or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator's email address info@ludmila-tours.com with the note "Withdrawal of consent to the processing of 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 persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or these documents independently acquaints with the specified 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 dissemination do not apply in cases of processing personal data in state, public and 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 carries out storage of personal data in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract, a party to which, beneficiary or guarantor under which is the subject of personal data.
8.9. The condition for termination of processing of personal data may be the achievement of the purposes of processing personal data, expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data or a request to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Obtained Personal Data9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transfer of the obtained information via information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data10.1. Before starting 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 subjects of personal data of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intention to carry out processing of personal data).
10.2. Before submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.
11. Confidentiality of Personal DataThe Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions12.1. The User can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email spb.ludmila-tours@yandex.ru.
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 is freely available on the Internet at https://ludmila-tours.com/privacy.