These Regulations on the Personal data protection policy (hereinafter - the Regulations) are an official document of the Limited Liability Company "Room-Service" (hereinafter LLC Room-Service, or the Operator), located at the address: P.O. Box 428000, Chuvashia, Cheboksary city, Lenin Avenue , bldg. 2 (hereinafter referred to as the Company / Operator / Seller), and determines the procedure for processing and protecting information about individuals (hereinafter referred to as the Website Visitor / User / Buyer / Guest) who use services, information or programs (including loyalty programs), and also purchasing Goods and Services of the Company through the official website (chuvashiyahotel.ru) located at the domain name chuvashiyahotel.ru (hereinafter referred to as the Website), and / or purchasing Goods and Services at the place of direct location of the Company.
The most important condition for the implementation of the objectives of the activities of LLC Room-Service (hereinafter referred to as the Operator) is to ensure the necessary and sufficient level of information security, which among other things includes personal data.
The policy concerning the processing of personal data at LLC Room-Service determines the procedure for collecting, storing, transferring and other types of personal data processing, as well as information on the implemented requirements for personal data protection.
The personal data of the User / Buyer is processed in accordance with the Federal Law "About Personal Data" No. 152, in accordance with the current Russian Federation legislation.
Collection, storage, transfer and other types of personal data processing in LLC Room-Service are carried out at the Chuvashia hotel, located in Chuvashia, Cheboksary city, Lenin Avenue, building 2, P.O. Box 428000.
The User provides the following information during registration on the website:
Name, family name, middle name – to book the room or place restaurant order.
Telephone number, which is used for contacting the guest or to send free SMS-confirmation of the booking or restaurant order. SMS-confirmation is sent only after personal guest agreement. The fact of personal agreement is a tick in the box "I want to receive a free SMS-confirmation of the booking" on the website chuvashiyahotel.ru booking form.
E-mail address, which is used for sending booking confirmation and possibility to cancel the booking.
The room category, the dates of arrival and departure, the selected rate plan, the number of rooms, the number of persons - the necessary information to identify the guest and make a reservation.
By providing personal data to the Seller the Site Visitor / User / Buyer agrees to data processing by the Seller in order to fulfill the Seller's obligations to the Site Visitor / User / Buyer under this Public Offer, promotion of Seller’s goods and services, conducting e-mail and SMS surveys , monitoring the results of marketing campaigns, customer support, organizing the delivery of goods to Buyers, holding prize drawings among Site Visitors / Users / Buyers, monitoring the satisfaction of the Site Visitor / User / Buyer, as well as the quality of services provided by the Seller.
The processing of personal data means any action (operation) or a set of actions (operations) performed by using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (including transfer to third parties, not excluding cross-border transfer, if the need for it arose in the course of fulfilling obligations), depersonalization, blocking, deletion, destruction of personal data.
Personal data composition
Personal data is consisting of any information relating directly or indirectly to a specific or identifiable individual (subject of personal data). A detailed list of personal data is recorded in the local regulatory documentation of LLC Room-Service.
All personal data processed by LLC Room-Service is confidential, strictly protected in accordance with the law.
The purposes of personal data processing
LLC Room-Service processing personal data for following purposes:
registration of labor and other contracts, human resources, accounting, tax accounting, on the grounds provided for by Article 22 of the Federal Law from June 27, 2006 No. 152, 85-90 of the Labor Code of the Russian Federation;
organizing and conducting by LLC Room-Service (including with the involvement of third parties) loyalty programs, marketing and / or advertising campaigns, researches, surveys and other events;
fulfillment of obligations under the retail sale contract in the Chuvashia Hotel;
fulfillment of obligations within the framework of the officially published information about the services of the Chuvashia hotel on the official websites;
delivery of other services to the guests with personal data;
promotion of services and / or goods of LLC Room-Service and / or its partners on the market by making direct contacts with customers using various means of communication, including, but not limited to, by phone, e-mail, mailing, in social media, etc;
for other purposes, if the actions of the Company do not contradict the current legislation.
LLC Room-Service in order to properly fulfill its obligations as the Operator processes the following personal data required for the proper fulfillment of contractual obligations:
personal data of the Operator's employees who are in labor relations with the Operator;
personal data of other individuals, including, but not limited to, those who are in contractual, student, civil relations with the Operator, including, but not limited to, students, buyers, regular customers, professional athletes, candidates.
THE ORDER OF COLLECTION, STORAGE, TRANSFER AND OTHER TYPES OF PERSONAL DATA PROCESSING.
Personal data processing carried out without the use of automation tools, is carried out in such a way that for each category of personal data it is possible to determine the storage locations of personal data (material carriers). The Operator has established a list of persons who process personal data or have access to it. Separate storage of personal data (material carriers) is provided, the processing of which is carried out for various purposes. The Operator ensures the safety of personal data and takes measures to exclude unauthorized access to personal data.
Personal data processing carried out by using automation tools is subject to the following actions:
The Operator takes technical measures aimed at preventing unauthorized access to personal data and (or) transferring it to persons who do not have the right to access such information;
security tools are configured to timely detect facts of unauthorized access to personal data;
technical resources of automated personal data processing are isolated in order to prevent impact on it, as a result of which its functioning may be disrupted;
The Operator makes a backup copy of data in order to be able to immediately restore personal data modified or destroyed due to unauthorized access to it;
carries out constant control over ensuring the level of protection of personal data.
INFORMATION ON IMPLEMENTED REQUIREMENTS FOR PERSONAL DATA PROTECTION.
The Operator carries out the following activities:
determines threats to the security of personal data during its processing, forms threat models;
based on the threat model develops a personal data protection system that neutralizes perceived threats using the methods and systems for protecting personal data provided with corresponding class of information systems;
forms a plan for checking the readiness of new information security tools for use with drawing up conclusions about the possibility of its operation;
carries out installation and authorizing information security tools in accordance with the operational and technical documentation;
conducts trainings of persons using information security tools used in information systems, the rules for working with it;
keeps records of the used information security tools, operational and technical documentation for it, carriers of personal data;
keeps records of persons admitted to work with personal data in the information system;
has the right to initiate proceedings and draw up opinions on the facts of non-compliance with the storage conditions of personal data carriers, the use of information protection means that may lead to a violation of the confidentiality of personal data or other violations leading to a decrease in the level of protection of personal data, the development and adoption of measures to prevent possible dangerous consequences of such violations;
has descriptions of the personal data protection system.
For the development and implementation of specific measures to ensure the security of personal data during its processing in the information system, the Operator or an authorized person is responsible for the information technology division of the Operator. Persons whose access to personal data processed in the information system is necessary for the performance of official (labor) duties are allowed to the corresponding personal data on the basis of the list approved by the Operator.
Requests from users of the information system for obtaining personal data, as well as the facts of providing personal data for these requests are registered by automated means of the information system in the electronic journal of requests.
The content of the electronic journal of requests is periodically checked by the relevant officials (employees) of the Operator or an authorized person. If violations of the procedure for providing personal data are found, the Operator or an authorized person immediately suspends the provision of personal data to users of the information system until the reasons for the violations are identified and these reasons are eliminated.
RIGHTS AND OBLIGATIONS OF THE OPERATOR
LLC Room-Service as the Operator of personal data has the right to:
defend its interests in court;
provide personal data to third parties if it is stipulated by the current legislation (tax, law enforcement agencies, etc.);
refuse to provide personal data in cases stipulated by the law;
to use personal data without persons agreement in cases stipulated by the law.
The Operator has the right to send informational messages, including advertising messages, to the e-mail and mobile phone of the User / Buyer with his consent, expressed through the performance of actions that uniquely identify this subscriber and allow him to reliably establish his will to receive the message. The User / Buyer has the right to refuse to receive advertising and other information without explaining the reasons by informing LLC Room-Service about his refusal by phone +7 (835) 262-45-77 и +7 (835) 262-45-67, or by sending a corresponding application to the Operator's email address: email@example.com.
Service messages informing the User / Buyer about the order and the stages of its processing are sent automatically and cannot be rejected by the User / Buyer.
Withdrawal of consent to the personal data processing is carried out by withdrawal of acceptance of this Public Offer.
The Operator receives information about the ip-address of the website chuvashiyahotel.ru visitor. This information is not used to identify the visitor.
The Operator is not responsible for the information provided by the User / Buyer on the website in a public form.
The Operator has the right to record telephone conversations with the User / Buyer. At the same time, the Operator undertakes: to prevent attempts of unauthorized access to information received during telephone conversations, and / or transfer it to third parties not directly related to the execution of Orders, in accordance with clause 4 of Art. 16 of the Federal Law “About Information, Information Technologies and Information Protection”.
RIGHTS AND OBLIGATIONS OF THE PERSONAL DATA BEARER
The personal data bearer has the right:
to demand clarification of his personal data, blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect his rights;
to require a list of his personal data processed by the Operator and the source of its receipt;
to receive information about the timing of processing his personal data, including the timing of its storage;
to require notification of all persons who have previously been provided with incorrect or incomplete personal data about all exceptions, corrections or additions made to it;
to appeal to the authorized organization for the rights protection of personal data bearer or in a judicial proceeding against unlawful actions or omissions in the processing of his personal data;
to protect his rights and legitimate interests including compensation for damages and (or) compensation for moral damage in court.
This Policy is subject to change, addition in the event of new legislative acts and special regulations on the processing and protection of personal data.
This Policy is an internal document of LLC Room-Service and is subject to placement on the official website chuvashiyahotel.ru
Control over the fulfillment of the requirements of this Policy is carried out by the person responsible for ensuring the security of personal data of LLC Room-Service.