Policy on the Processing of Personal Data

This Personal Data Processing Policy 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 measures to ensure the security of personal data implemented by LLC “Legenda SSSR” (hereinafter referred to as the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy, as its most important goal and condition for carrying out 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.

2.1. Automated processing of personal data — processing of personal data using computer 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 collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the web address https://parkhotelostrov.ru.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that enable their processing.
2.5. Anonymization of personal data — actions that make it impossible, without the use of additional information, to determine the ownership of personal data by a specific User or another subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, 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://parkhotelostrov.ru.
2.9. Personal data permitted by the subject of personal data for distribution — personal data to which the subject of personal data has granted access to an unlimited number of persons by giving consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor of the website https://parkhotelostrov.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 circle of persons (transfer of personal data) or at acquainting an unlimited circle of persons with personal data, including publication of personal data in mass media, placement in 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 state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the permanent destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or resulting in the destruction of physical media of personal data.

5.1. Processing of personal data shall be carried out on a lawful and fair basis.
5.2. Processing of personal data shall be limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not allowed.
5.3. It is not permitted to combine databases containing personal data that are processed for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and scope of the processed personal data shall correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of their processing shall be ensured. The Operator shall take the necessary measures and/or ensure that incomplete or inaccurate data are deleted or clarified.
5.7. Personal data shall be stored in a form that allows identifying 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 an agreement to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or if the necessity to achieve such purposes is lost, unless otherwise provided by federal law.

7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, or an act of another body or official subject to execution under the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data 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. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out of personal data to which access has been granted by the personal data subject to an unlimited number of persons or at his/her request (hereinafter — publicly available personal data).
7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.

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. Personal data of the User shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or when the personal data subject has given consent to the Operator to transfer data to a third party for the performance 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 at the email address admin@parkhotelostrov.ru with the subject line “Update of personal data.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is established by contract or applicable law.
The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator via email at admin@parkhotelostrov.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 providers, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject shall independently familiarize themselves with these documents. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Restrictions established by the personal data subject on transfer (except for granting access), as well as on processing or conditions of processing (except for access) of personal data permitted for distribution, shall 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 stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating the processing of personal data may include the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject, the withdrawal of consent by the personal data subject, a request to terminate the processing of personal data, or the detection of unlawful processing of personal data.

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

10.1. Before commencing 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 such cross-border transfer (this notification is submitted separately from the notification of intent to process personal data).
10.2. Prior to submitting the above-mentioned notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.

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

12.1. The User may obtain any clarifications regarding the processing of his/her personal data by contacting the Operator via email at admin@parkhotelostrov.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 freely available on the Internet at https://parkhotelostrov.ru.