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Personal data processing and protection policy.

1. General terms

This personal data processing policy was created in accordance with the Federal law No. 152-FZ of 27.07.2006 "On personal data", it defines the procedure for processing personal data and ensures the security measures of LLC "Promotion management Company S. E. A." (hereinafter referred to as the Operator).

1. The operator sets as its goal and condition for the realization of its work the rights and freedoms of man and citizen during processing their personal data, including protection their rights for personal and family privacy.

2. This Operator's policy on personal data processing (hereinafter referred to as the “Policy”) applies to all information that the Operator can obtain about website visitors http://keydomhotels.com.

3. This privacy policy applies only to this website. When users click on the links, they leave our site and access sites of other companies. The operator is not responsible for the privacy and security policies or content of such companies' websites, and users should always check the privacy policies of all websites they have accessed.

2. General definitions used in Policy 

1. Automated personal data processing means any action or set of actions performed with the use of automation tools with personal data;

2. Personal data blocking – temporary discontinuation of processing of personal data (except for cases when processing is necessary to clarify personal data);

3. Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address http://keydomhotels.com;

4. Personal data Information system — a set of personal data contained in databases, as well as information technologies and technical means that ensure their processing;

5. Depersonalization of personal data — actions that make it impossible to determine the identity of personal data to a specific User without using additional information;

6. Personal data processing means 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 (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, removal, deletion of the personal data;

7. Operator – a state or municipal body, legal entity or individual that independently or jointly with other organizes and (or) performs the processing of personal data, as well as determines the purposes of processing personal data, the content of personal data to be processed, actions (operations) performed with personal data;

8. Personal data – any information directly or indirectly related to a particular or defined User of the web site http://keydomhotels.com;

9. User – any visitor of the website http://keydomhotels.com;

10. Personal data provision – actions aimed at disclosure of personal data to a certain person or a certain range of persons;

11. Personal data distribution – any actions aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or at familiarization with personal data of an unlimited number of persons, including disclosure of personal data in the mass media, its placement in information and telecommunications networks, or providing access to personal data in any other way;

12. Transboundary 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;

13. Personal data removal – actions that make it impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data become destroyed.

3. The Operator may process the following User personal data:

1. Surname, first name and patronymic;

2. E-mail;

3. Contact phone;

4. Date and place of birth;

5. Photos;

6. Also the website collects and processes some anonymous data about visitors (including "cookies") through the services of Internet statistics (Yandex Metric and Google Analytics and others).

7. The above-mentioned data hereinafter referred to as the “Personal data”.

 

4. Purpose of collecting personal data 

1. The purposes of processing of the user's personal data are: to inform the user by sending informative emails, to provide the user with access to the services, information and/or materials contained on the website.

2. The Operator also has the right to send notifications to the user about new products and services, special offers and various events. The user can always refuse to receive information messages by sending a notification to the Operator's email address welcome@keydomhotels.com marked "Unsubscribe from notifications of new products and services and special offers".

3. Depersonalized user data collected through Internet statistics services is used to collect information about user actions on the site in order to improve the quality of the site: optimize the structure and content, configure security and data transfer speed.

 

5. Legal grounds for processing personal data

1. The Operator processes the user's personal data only if they are filled in and/or sent by the user independently via special forms located on the site http://seacompany-hotels.com. By filling out the appropriate forms and/or sending personal data to the Operator, the user agrees to this Policy.

2. The Operator processes depersonalized data about the user if this is allowed in the user's browser settings (including saving cookies and using JavaScript technology).

 

6. Procedure for collecting, storing, transferring and other types of personal data processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures need to meet the requirements of current legislation in the field of personal data protection.

1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.

2. The User's personal data will never be transferred to third parties, except cases related to the implementation of current legislation.

3. If inaccuracies in personal data are detected, the u      ser can update them independently by sending a notification to the Operator's email address welcome@keydomhotels.com marked "Updating personal data".

4. The term of processing of personal data is unlimited. The user can revoke the consent to the processing of personal data at any time by sending a notification to the Operator's email address welcome@keydomhotels.com marked "Revocation of consent to the processing of personal data".


7. Transboundary transfer of personal data

1. The Operator must ensure that the rights of the subject of the personal data are reliably protected by the foreign state to which the personal data is intended to be transferred prior to the start of transboundary transfer of personal data.

2. Transboundary transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if the subject of the personal data agrees in writing form with the transboundary transfer of his/her personal data and/or performance of the contract (one of the sides of which is the subject of the personal data).


8. Final terms

1. The User can get any clarification on issues related to the processing of the personal data by contacting the Operator by email welcome@keydomhotels.com

2. This document will reflect any change made by Operator in the personal data processing and protection policy. The policy is valid permanently until it is replaced with a new version.