Privacy Policy of Diamond Apartments
1. General Provisions
This personal data processing policy is drawn up in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "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 undertaken by the Apart-hotel "Diamond Apartments" (hereinafter referred to as the Operator).
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1.1. The Operator's most important goal and condition for carrying out its activities is the observance of human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal and family secrets.
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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://diamond-apart.com/.
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 — temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).
- 2.3. Website — 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://diamond-apart.com/.
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2.4. Information system of personal data — a set of personal data contained in databases, and information technologies and technical means ensuring their processing.
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2.5. Anonymization of personal data — actions that result in the impossibility to determine the ownership of personal data by a specific User or other subject of personal data without the use of additional information.
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2.6. Processing of personal data — any action (operation) or a 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), anonymization, blocking, deletion, destruction of personal data.
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Operator — a state body, municipal body, legal or physical person, which independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
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2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://diamond-apart.com/.
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2.9. Personal data allowed by the subject of personal data for dissemination — personal data, access to which is granted to an unlimited number of persons by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for dissemination).
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2.10. User — any visitor to the website https://diamond-apart.com/.
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2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
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2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at making personal data known to an indefinite circle of persons, including the publication of personal data in the media, placement in information and telecommunications networks, or providing access to personal data in any other way.
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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 natural or foreign legal person.
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2.14. Destruction of personal data — any actions that result in the irreversible destruction of personal data with the impossibility of further restoration of the content of personal data in the personal data information system and/or result in the destruction of physical media of personal data.
3. Basic Rights and Obligations of the Operator
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3.1. The Operator has the right to:
— receive accurate information and/or documents containing personal data from the data subject;
— in the event of the data subject's withdrawal of consent to the processing of personal data, as well as in the case of a request to cease the processing of personal data, the Operator is entitled to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
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3.2. The Operator is obliged to:
— provide the data subject, at their request, with information regarding the processing of their personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the necessary information to the authorized body for the protection of the rights of personal data subjects within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;
— 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;
— fulfill other obligations stipulated by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
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4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other personal data subjects, 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;
— request the Operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the declared purpose of processing, and to take measures provided by law to protect their rights;
— stipulate the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;
— withdraw consent to the processing of personal data and to submit a request to cease the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or to the court regarding unlawful actions or inactions of the Operator during the processing of their personal data;
— exercise other rights provided by the legislation of the Russian Federation.
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4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator about the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without their consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
- 5.1. Personal data processing is carried out on a lawful and fair basis.
- 5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
- 5.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not permitted.
- 5.4. Only personal data that meet the purposes of their processing are subject to processing.
- 5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes of processing is not permitted.
- 5.6. The accuracy, sufficiency, and, in necessary cases, relevance of personal data are ensured during personal data processing, in relation to the purposes of personal data processing. The Operator takes necessary measures and/or ensures that incomplete or inaccurate data are deleted or clarified.
- 5.7. Personal data is stored in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing unless the storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
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Informing the User by sending emails
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Personal data:
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Philosophical beliefs
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Legal grounds:
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Federal Law "On Information, Information Technologies and Protection of Information" dated 27.07.2006 No. 149-FZ
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Types of personal data processing:
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Transfer of personal data
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7. Conditions for Personal Data Processing
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7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
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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, for the exercise of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
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7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body, or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
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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.
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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.
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7.6. Personal data that has been made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data) is processed.
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7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for Collecting, Storing, Transmitting, and Other Types of Personal Data Processing
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.
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8.1. The Operator ensures the security of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
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8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
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8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address info@diamond-apart.com with the note "Updating personal data."
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8.4. The period for processing personal data is determined by achieving the purposes for which the personal data was collected unless otherwise provided 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 via email at the Operator's email address info@diamond-apart.com with the note "Withdrawal of consent to the processing of personal data."
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8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is responsible for familiarizing themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
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8.6. Restrictions established by the personal data subject on the transfer (excluding provision of access), as well as on the processing or conditions of processing (excluding access) of personal data permitted for dissemination, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
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8.7. The Operator ensures the confidentiality of personal data during its processing.
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8.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than required by the purposes of personal data processing unless the storage period of personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
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8.9. The condition for terminating the processing of personal data may be 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, or a request to cease 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 Received Personal Data
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9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.
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9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the obtained information through information and telecommunication networks or without such networks.
10. Transborder Transfer of Personal Data
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10.1. Before starting activities related to the transborder transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects about its intention to carry out a transborder transfer of personal data (this notification is sent separately from the notification of the intention to process personal data).
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10.2. Before submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the transborder transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
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12.1. The User can obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at info@diamond-apart.com.
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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.
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12.3. The current version of the Policy is freely available on the Internet at https://diamond-apart.com/privacy/.