Personal Data Processing Policy

1. General provisions
This Personal Data Processing Policy is made in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (the “Personal Data Law”) and defines the procedure for processing personal data and the measures taken by Ivan Durian Tour Co. Ltd (the “Operator”) to ensure the security of personal data.
1.1. The Operator’s primary goal and condition for its activities is to respect the rights and freedoms of individuals when processing their personal data, including protecting the rights to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding the processing of personal data (the “Policy”) applies to all information that the Operator may receive about visitors to the website https://ivandurian.ru/.

2. Key terms used in this Policy
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except when processing is necessary to clarify personal data).
2.3. Website — a set of graphic and information materials, as well as computer programs and databases, that ensure their availability on the Internet at https://ivandurian.ru/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that make it impossible, without the use of additional information, to determine which specific User or other subject the personal data belongs to.
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), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state or municipal authority, or a legal or natural person, which independently or jointly with others organizes and/or carries out the processing of personal data, and determines the purposes of processing personal data, the composition of personal data to be processed, and 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://ivandurian.ru/.
2.9. Personal data permitted by the personal data subject for distribution — personal data to which access is provided to an unlimited circle of persons by the personal data subject by giving consent for processing such data for distribution under the procedure provided by the Personal Data Law.
2.10. User — any visitor to the website https://ivandurian.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle 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 making personal data available to an unlimited circle of persons, including publication in the 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 an authority of a foreign state, a foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irretrievably with the impossibility of further restoring the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.

3. Main rights and obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— in case of withdrawal by the personal data subject of consent to processing and/or in case of a demand to cease processing, continue processing without consent if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations stipulated by the Personal Data Law and by-laws, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize personal data processing in accordance with the legislation of the Russian Federation;
— respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of personal data subjects, upon its request, the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as other unlawful actions in relation to personal data;
— cease transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— fulfill other obligations provided by the Personal Data Law.

4. Main rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
— receive information related to the processing of their personal data, except in cases provided by federal laws. Information is provided by the Operator in an accessible form and must not contain personal data relating to other subjects, except in cases where there are legal grounds for disclosure. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the Operator clarify personal data, block or destroy them if personal data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take statutory measures to protect their rights;
— set a condition of prior consent when processing personal data for the purposes of marketing goods, works, and services;
— withdraw consent to personal data processing and require cessation of processing;
— appeal unlawful actions or inaction of the Operator in processing personal data to the authorized body for the protection of personal data subjects or in court;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing is limited to achieving specific, pre-determined, and lawful purposes. Processing incompatible with the purposes of collecting personal data is not allowed.
5.3. It is not allowed to combine databases containing personal data that are processed for purposes incompatible with each other.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes. Excessive processing relative to the stated purposes is not allowed.
5.6. When processing personal data, accuracy, sufficiency, and, where necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures the taking of such measures to remove or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that enables identification of the personal data subject no longer than required by the purposes of processing, unless a longer storage period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or depersonalized upon achievement of processing purposes or when they are no longer needed, unless otherwise provided by federal law.

6. Purposes of personal data processing
Purpose of processing — free consultation and booking; personal data processed: surname, name, patronymic; phone numbers; district / pickup beach.
Legal grounds — licensed excursion agency (TAT No. 34/03251).
Types of processing — collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.

7. Conditions for personal data processing
7.1. Processing is carried out with the consent of the personal data subject.
7.2. Processing is necessary for achieving purposes provided by an international treaty of the Russian Federation or by law, and for the Operator’s performance of functions, powers, and duties imposed by the legislation of the Russian Federation.
7.3. Processing is necessary for the administration of justice, execution of a judicial act or an act of another body or official to be executed under the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, and for the conclusion of a contract at the initiative of the personal data subject or a contract under which the subject will be a beneficiary or guarantor.
7.5. Processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data made publicly available by the personal data subject or at their request is performed.
7.7. Processing of personal data subject to publication or mandatory disclosure under federal law is performed.

8. Procedure for collection, storage, transfer, and other processing of personal data
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with applicable personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except as required by applicable law or when the personal data subject has given consent to transfer data to a third party to fulfill obligations under a civil law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notice to the Operator at ivanduriantour@gmail.com with the subject “Personal data update”.
8.4. The term of processing is determined by the achievement of the purposes for which personal data were collected, unless a different term is provided by contract or applicable law. The User may revoke consent to processing at any time by sending a notice to ivanduriantour@gmail.com with the subject “Withdrawal of consent to personal data processing”.
8.5. All information collected by third-party services, including payment systems, communications providers, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject should review the relevant documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on transfer (other than granting access), as well as on processing or conditions of processing (other than access) of personal data permitted for distribution, do not apply in cases of processing for state, public, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that enables the identification of the personal data subject no longer than required by the purposes of processing, unless a longer period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating processing may include achievement of the purposes of processing, expiration of the consent term, withdrawal of consent by the personal data subject or a demand to cease processing, as well as detection of unlawful processing.

9. List of actions performed by the Operator with received personal data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with receiving and/or transmitting the obtained information via information and telecommunication networks or without such means.

10. Cross-border transfer of personal data
10.1. Before commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects of its intention (such notification is sent separately from the notification of intent to process personal data).
10.2. Prior to submitting the above notification, the Operator must obtain from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom personal data are planned to be transferred, the relevant information.

11. 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 personal data subject, unless otherwise provided by federal law.

12. Final provisions
12.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at ivanduriantour@gmail.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available on the Internet at https://ivandurian.ru/privacypolicy.