The Policy of Processing Data
The policy of processing data of the hotel “Liga”
1. General information.
The policy of processing of personal data (hereinafter - the Policy) is developed according to the Federal law of July 27, 2006. No.152-ФЗ “About personal data” (hereinafter - ФЗ-152), the Federal law “About Information, Informational Technologies and Information Security” No.149-ФЗ of July 27, 2006, the Resolution of the Government of the Russian Federation of 15.09.2008 No.687 “About the approval of the Regulation on the specifics of processing personal data carried out without the use of automation tools”, the Resolution of the Government of the Russian Federation of November 1, 2012 No.1119 “About the approval of the requirements for the protection of personal data when processing them in personal data information systems”, the Resolution of the Government of the Russian Federation of September 15, 2008 No.687 “About the approval of the Regulation on the specifics of processing Personal data performed without the use of automation tools", for EU citizens: General Data Protection Regulation (GDPR).
This Policy defines the procedure for the processing of personal data and measures to ensure the security of personal data in the Hotel “Liga” (hereinafter – the Operator, the Hotel) in order to protect the rights and freedoms of a person (citizen) when processing his personal data, including protection of privacy rights life, personal and family secrets.
The following basic concepts are used in the Policy:
personal data - any information related directly or indirectly to a particular or determined individual (subject of personal data);
operator of personal data (operator) or controller - a state authority, a municipal body, a legal entity (the Hotel “Liga”) or an individual, independently or jointly with others, organizing and (or) processing personal data, defining personal data processing purposes, data to be processed, actions (operations) performed with personal data;
personal data processing - any action (operation) or set of actions (operations) with personal data, performed with or without the use of automation tools. Personal data processing includes, but is not limited to: collection, recording, systematization, accumulation, storage, updating (modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
automated processing of personal data - processing of personal data by means of computer facilities;
distribution of personal data - actions aimed at disclosing personal data to an undefined persons;
provision of personal data - actions aimed at disclosing personal data to a certain person or persons;
blocking of personal data - temporary termination of processing of personal data (except for cases when processing is necessary for specification of personal data);
destruction of personal data - actions, as a result of which it becomes impossible to restore the contents of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed;
depersonalization of personal data - actions resulting in the impossibility of using additional information to determine the ownership of personal data to a specific subject of personal data;
information system of personal data - a set of personal data contained in databases and providing their processing of information technologies and technical means;
cross-border transfer of personal data – the transfer of personal data on the territory of the foreign state to authority of the foreign state, the foreign ownership or the foreign legal entity;
processor - performer, engaged in the processing of personal data (collect, store, structure, modify, delete, etc.).
2. Principles and terms of personal data processing.
The Hotel performs processing of personal data to execute the following:
- Resolutions of the Government of the Russian Federation of October 09, 2015 No.1085 “About the approval of Rules of providing hotel services in the Russian Federation”;
- The law of the Russian Federation of June 25, 1993 No.5242-1 “About the right of citizens of the Russian Federation for freedom of movement, the choice of the place of stay and residence within the Russian Federation”;
- Rules of migration registration of foreign citizens and persons without citizenship in the Russian Federation, approved by the Resolution of the Government of the Russian Federation of January 15, 2007 No.9 “About a procedure of migration registration of foreign citizens and persons without citizenship in the Russian Federation”;
- the order of the Ministry of Internal Affairs of the Russian Federation of November 23, 2017 No. 881;
- other federal laws and regulatory legal acts adopted on their basis that regulate relations related to the activities of the operator; contracts made between the operator and the subject of personal data; consent to the processing of personal data (in cases not directly provided for by the legislation of the Russian Federation, but corresponding to the powers of the operator).
Methods of processing personal data:
- using automation tools;
- without the use of automation.
In the information systems owned by the Hotel, the following personal data is processed:
- surname, name, patronymic of the subject of personal data;
- e-mail address of the subject of personal data;
- city of registration;
- citizenship;
- mobile phone of the subject of personal data;
- terms of the application of the personal data subject;
- financial information, such as credit card and bank account numbers (if paid through the Site) of the personal data subject
The processing of personal data is carried out for the purpose of implementing any actions that are not inconsistent with the legislation of the Russian Federation with respect to personal data aimed at achieving the objectives: online booking by the client of the selected accommodation facility; preparation of accounting documents; obtaining feedback on the quality of the service of the booked accommodation facility.
The Hotel has the right to transfer personal data to the authorities of inquiry and investigation, to other authorized bodies on the bases provided by the current legislation of the Russian Federation.
When processing personal data the Hotel applies legal, organizational and technical measures for safety of personal data. The hotel observes requirements of confidentiality of the personal data established to Art.7 of the Federal law “About Personal Data”, takes the measures provided by the p.2 of Art.18.1, p.1 Art.19 of the Federal law “About Personal Data”.
The term for the termination of the processing of personal data is the achievement of the purposes of processing personal data, the expiration of the consent or withdrawal of the consent of the subject of personal data to the processing of his personal data, as well as the identification of improper processing of personal data. The application (withdrawal) of the consent of the processing of personal data to the subject of personal data must be sent to the address of the Hotel at: St. Petersburg, Ligovsky Prospekt, 63 Litera A.
The storage of personal data is carried out in a form that allows the subject of personal data to be determined no longer than the purpose of personal data processing requires.
When carrying out the storage of personal data, the personal data operator uses databases located in the territory of the Russian Federation, in accordance with the p.5 of Art.18 of the Federal law “About Personal Data”.
The evaluation of the harm that may be caused to the subjects of personal data in case of violation of the requirements of the Federal Law No.152-ФЗ of July 27, 2006 “About personal data” is determined in accordance with the Civil Code of the Russian Federation.
The hotel may charge the processing of personal data to a third party on the basis of the agreement. An essential condition for such a contract is the availability of the right of this person to process personal data, the obligation to provide the specified person with the confidentiality of personal data and the safety of personal data when processing them. Reservation of the selected accommodation is carried out on the basis of the agreement by TrevelLine (processor) e-mail: trevelline.ru, visa support is provided by iVisa company (JSC “Vizovy Tsentr”) e-mail: support@iVisa.ru, interaction with migration authorities is carried out from using the software "ELPOST" by the company "Federal Hotel Service" e-mail: federalhotelservice.ru.
Principles of processing personal data.
The processing of personal data by the Hotel is carried out on the basis of the following principles:
- legality and fair basis;
- restrictions on the processing of personal data by the achievement of specific, pre-determined and legitimate purposes;
- preventing the processing of personal data incompatible with the purposes of collecting personal data;
- preventing the unification of databases containing personal data, processing of which is carried out for purposes incompatible with each other;
- processing only those personal data that meet the purposes of their processing;
- compliance of content and volume of processed personal data with the stated processing objectives;
- preventing the processing of personal data that is excessive in relation to the stated purposes of processing them;
- ensuring the accuracy, adequacy and relevance of personal data in relation to the purposes of processing personal data;
- destruction or depersonalization of personal data upon the achievement of the purposes of their processing or in the event of a loss of the need to achieve these aims, if the Operator cannot eliminate the admitted violations of personal data, unless otherwise provided by federal law.
Terms of personal data processing.
The Hotel performs processing of personal data in the presence of at least one of the following terms:
- processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
- processing of personal data is necessary for achievement of the aims, provided by the international treaty of the Russian Federation or the law, for exercise and realization of the functions assigned by the legislation of the Russian Federation to the operator, powers and duties;
- processing of personal data is necessary for the administration of justice, enforcement of a judicial act, an act of another body or official subject to enforcement in accordance with the law of the Russian Federation on enforcement proceedings;
- processing of personal data is necessary for the performance of a contract to which the subject of personal data or a beneficiary or guarantor is a party, as well as to make a contract on the initiative of a personal data subject or a contract whereby the personal data subject will be a beneficiary or guarantor;
- 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 purposes, provided that the rights and freedoms of the subject of personal data are not thereby violated;
- processing of personal data, access of an unlimited range of persons to which is provided by the subject of personal data or at his request (hereinafter - publicly available personal data);
- processing of the personal data which is subject to publication or obligatory disclosure according to the federal law is carried out.
Biometric personal data: data which characterize physiological and biological features of the person on the basis of which it is possible to identify his personality - biometric personal data - can be processed by the Hotel only if there is a consent in writing of the subject.
Cross-border transfer of personal data: the Hotel is obliged to ensure that the foreign state to which the transfer of personal data is intended to provide adequate protection of the rights of subjects of personal data, prior to the commencement of such transfer.
Cross-border transfer of personal data in the territory of the foreign states which are not providing adequate protection of the rights of subjects of personal data can be carried out in the following cases:
– consent existence in writing of the subject of personal data on cross-border transfer of his personal data;
- execution of the contract which party is the subject of personal data.
Policy of usage of the “cookies” files.
The “cookies” files are the part of the data which are stored on the user's computer, connected to information on the user. The usage of the “cookies” files is not connected with any personal information, in difference from information on the website in any way. Both permanent and session “cookies” files are used. Session (session, temporary) “cookies” are deleted as soon as you close the browser. Persistent “cookies” are stored on the user's hard drive. They can be deleted by following the instructions of your browser.
3. Rights of the personal data subject.
The subject of personal data decides to provide his personal data and agrees to their processing freely, at will and in his interest. Consent to the processing of personal data can be given by the subject of personal data or his representative in any form that allows to confirm the fact of its receipt, unless otherwise provided by federal law.
The subject of personal data has the right to receive from the Hotel information regarding the processing of his personal data, if such a right is not restricted in accordance with federal laws. The subject of personal data has the right to demand the specification of his personal data, their blocking or destruction in the case that personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, and also take measures provided by law to protect his rights.
The Hotel immediately stops at the request of the personal data subject the processing of his personal data for advertising purposes.
4. Final provisions.
Other rights and duties of the Hotel as a personal data operator are determined by the legislation of the Russian Federation in the field of personal data, the data protection regulations (General Data Protection Regulation, GDPR).
The current version of Policy on paper is stored at: St. Petersburg, Ligovsky Prospekt, 63, Litera A.
To get access to the information, to ask questions of our rules of protection of confidentiality, to change the preferences on obtaining advertizing materials or to file a complaint, contact us:
The Hotel “Liga”. 191040, St. Petersburg, Ligovsky Prospekt, 63, Litera A.
tel. +7 (812) 644-57-77
www.ligahotel.ru
While reviewing your personal written request, the Hotel guarantees the confidentiality of the information you provide.
