1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006. № 152-ФЗ “On personal data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Individual Entrepreneur Pavlichenkov A.I. (hereinafter referred to as the Operator), including those received from the guest (visitor) of the Lesnoy Terem hotel (31 Centralnaya street, Ostashevo village, settlement Petrovskoye, Chukhlomsky district, Kostroma region, Russia) or the user (visitor) of the website https://astashovo.com.
1.1. The operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about visitors to the website https://astashovo.com, as well as guests (visitors) of the Lesnoy Terem hotel (31 Centralnaya street, Ostashevo village, settlement Petrovskoye, Chukhlomsky district, Kostroma region, Russia).
2. Basic concepts used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data is a temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).
2.3. Website means a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://astashovo.com.
2.4. Information system of personal data means a set of personal data contained in databases, and providing their processing of information technologies and technical means.
2.5. Depersonalization of personal data means actions as a result of which it is impossible to determine, without using additional information, the ownership of personal data by a specific User or other subject of personal data.
2.6. Processing of personal data means any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator means a state body, a municipal body, a legal entity or an individual, independently or jointly with other persons organizing and (or) processing 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 means any information relating directly or indirectly to a specific or identifiable User.
2.9. Personal data permitted by the subject of personal data for dissemination – personal data, access of an unlimited number of persons to which is provided 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 Law on Personal Data (hereinafter – personal data permitted for distribution).
2.10. User means any guest (visitor) of the Lesnoy Terem hotel (Kostroma region, Chukhlomsky district, rural settlement Petrovskoye, Ostashevo village, Tsentralnaya street, 31) or a user (visitor) of the website https://astashovo.com.
2.11. Provision of personal data means actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquaintance with the personal data of an unlimited number of persons, including the disclosure of personal data in the mass 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 means the transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign individual or foreign legal entity.
2.14. Destruction of personal data means any actions as a result of which personal data is destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The operator has the following rights:
– to receive from the subject of personal data reliable information and / or documents containing personal data;
– if the subject of personal data withdraws consent to 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 Law on Personal Data;
– to 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, upon their request, with information regarding the processing of their personal data;
– to organize the processing of personal data in the manner prescribed 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 Law on Personal Data;
– to inform the authorized body for the protection of the rights of subjects of personal data at the request of this body the necessary information within 30 days from the date of receipt of such a request;
– to publish or otherwise provide unrestricted access to this Policy in relation to the processing of personal data;
– to take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
– to stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in cases provided for by the Law on Personal Data;
– to perform other duties provided for by the Law on Personal Data.
4. Basic rights and obligations of subjects of personal data
4.1. Personal data subjects have the right:
– to receive information regarding the processing of their personal data, with the exception of 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, unless there are legal 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 clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
– to put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
– to withdraw consent to the processing of personal data;
– to appeal to the authorized body for the protection of personal data or in court the illegal actions or inaction of the Operator when processing their personal data;
– to exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged:
– to provide the Operator with reliable data about yourself;
– to inform the Operator about the clarification (update, change) of their personal data.
5. Composition of personal data, consent to their processing
5.1. The operator can process the following personal data of the User:
- full name;
- contact address;
- contact phone numbers;
- email addresses;
- messenger addresses;
- place of work and position held;
- user data (location information);
- type and version of the OS;
- type and version of the browser;
- type of device and its screen resolution;
- source from where the user came to the site;
- from which site or for which advertising;
- OS and Browser language;
- which pages opens and to which buttons are pressed by the user;
- IP-address; passport data (when checking into the hotel “Lesnoy Terem”);
- data required to comply with the requirements of migration registration (when checking into the hotel “Lesnoy Terem”).
- Also on the website https://astashovo.com. the collection and processing of anonymized data about visitors (including cookies) takes place using Internet statistics services (Yandex Metrica and Google Analytics and others).
5.2. The above data hereinafter in the text of the Policy are united by the general concept of Personal data.
5.3. The processing of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.
5.4. The processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Law on Personal Data.
5.5. The User’s consent to the processing of personal data permitted for distribution is drawn up separately from other consents to the processing of their personal data. In this case, the conditions provided for, in particular, Art. 10.1 of the Law on Personal Data. The requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.
5.6.1 Consent to the processing of personal data allowed for distribution, the User provides to the Operator directly.
5.6.2 The operator is obliged, no later than three working days from the moment of receipt of the specified consent of the User, to publish information on the processing conditions, on the existence of prohibitions and conditions for the processing of personal data by an unlimited number of persons allowed for dissemination.
5.6.3 The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for distribution must be stopped at any time at the request of the subject of personal data. This requirement must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which must be terminated. The personal data specified in this requirement can be processed only by the Operator to whom it is sent.
5.6.4 Consent to the processing of personal data permitted for distribution ceases to be effective from the moment the Operator receives the request specified in clause 5.6.3 of this Policy in relation to the processing of personal data.
6. Principles of processing personal data
6.1. The processing of personal data is carried out on a legal and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
6.4. Only personal data that meet the purposes of their processing is subject to processing.
6.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data is ensured. The operator takes the necessary measures and / or ensures their adoption to remove or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that makes it possible to determine the subject of personal data, no longer than the purpose of processing personal data requires, 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. The processed personal data is destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
7. Purposes of personal data processing
7.1. The purpose of processing the User’s personal data is:
- to receive and process orders for services of individuals;
- to provide services to individuals;
- to comply with the requirements of the current legislation in the field of migration registration;
- to process incoming requests from individuals for the purpose of providing advice;
- to analyze the actions of an individual on the website and the functioning of the website;
- to conduct advertising and newsletters.
7.2. The Operator has the right to send the User notifications about new products and services, special offers and various events. The user can always refuse to receive informational messages by sending the Operator an email to the email address booking@astashovo.com with the note “Refusal of notifications about new products and services and special offers”.
7.3. Anonymized User data collected using Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content.
8. Legal basis for the processing of personal data
8.1. The legal grounds for the processing of personal data by the Operator are:
– Decree of the Government of the Russian Federation of November 18, 2020 N 1853 (as amended on April 1, 2021) “On approval of the Rules for the provision of hotel services in the Russian Federation”;
– federal laws, other regulations in the field of personal data protection;
– the consent of the Users to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User’s personal data if they are filled in and / or sent by the User independently through special forms located on the website https://astashovo.com; sent to the Operator by e-mail; sent in paper form, including when checking into the hotel “Lesnoy Terem”. By filling out the appropriate forms and / or sending their personal data to the Operator, the User agrees with this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the settings of the User’s browser (the storage of cookies and the use of JavaScript technology are enabled).
8.4. The subject of personal data independently decides on the provision of their personal data and gives consent freely, of their own free will and in their interest.
9. Conditions for processing personal data
9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or by law, for the implementation of the functions, powers and duties imposed by the legislation of the Russian Federation on the operator.
9.3. 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.
9.4. The processing of personal data is necessary for the execution of an agreement, to which the subject of personal data is a party or beneficiary or guarantor, as well as for concluding an agreement initiated by the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or guarantor.
9.5. The 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.
9.6. The processing of personal data, accessible to an unlimited number of persons approved by the subject of personal data or at their request (hereinafter known as publicly available personal data), is carried out.
9.7. The processing of personal data subject to publication or mandatory disclosure in accordance with the federal law, is carried out.
9.8. The processing of personal data is necessary to ensure compliance with the requirements of the migration legislation in the provision of hotel services.
10. The procedure for collecting, storing, transferring and other types of processing of personal data
10.1. 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 the current legislation in the field of personal data protection.
10.2. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
10.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except for cases related to the implementation 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 contract.
10.4. In the event of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator’s e-mail address booking@astashovo.com marked “Updating personal data”.
10.5. 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 contract or current legislation. The user can revoke their consent to the processing of personal data at any time by sending a notification to the Operator via e-mail to the email address of the Operator booking@astashovo.com with the note “Revocation of consent to the processing of personal data”.
10.6. All information that is collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and / or the User is obliged to independently familiarize themselves with the specified documents in a timely manner. The operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.7. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in the state, community and other public interests determined by law in Russia.
10.8. When processing personal data, the operator ensures the confidentiality of personal data.
10.9. The operator stores personal data in a form that makes it possible to determine the subject of personal data, no longer than the purpose of processing personal data requires, if the storage period for personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
10.10. A condition for terminating 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 or withdrawal of consent by the subject of personal data, as well as the identification of illegal processing of personal data.
11. List of actions performed by the Operator with the received personal data
11.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
11.2. The operator carries out automated and non-automated processing of personal data with the receipt and / or transmission of the information received via information and telecommunication networks or without it.
12. Cross-border transfer of personal data
12.1. Before starting the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state, to whose territory it is supposed to transfer personal data, provides reliable protection of the rights of subjects of personal data.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if the subject of personal data consent in writing to the cross-border transfer of their personal data and / or the execution of an agreement to which the subject of personal data is a party.
13. Confidentiality of personal data
The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Final provisions
14.1. The user can receive any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via booking@astashovo.com.
14.2. This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://astashovo.com/en/privacy-en/.