PERSONAL DATA PROCESSING POLICY
1. General ProvisionsThis Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “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 Non-Profit Organization “National Tourism Union” (NTU) (hereinafter referred to as the “Operator”).
1.1. The Operator considers respect for the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the right to privacy and personal and family secrets, to be its most important objective and condition for carrying out its activities.
1.2. This Operator's Personal Data Processing Policy (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website: https://gleefully-virtual-zinnia.tilda.ws/.
2. Basic Terms Used in the Policy2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data, except where processing is necessary to clarify the personal data.
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at: https://gleefully-virtual-zinnia.tilda.ws/.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions that make it impossible to determine, without the use of additional information, the affiliation of personal data with a specific User or another personal data subject.
2.6. Processing of personal data — any action or set of actions performed with or without the use of automation tools in relation to personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data and determines the purposes of processing personal data, the composition of personal data subject to processing, and the actions performed with such data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://gleefully-virtual-zinnia.tilda.ws/.
2.9. Personal data permitted by the data subject for dissemination — personal data to which access by an unlimited number of persons has been granted by the data subject through consent to the processing of personal data permitted for dissemination in accordance with the procedure established by the Personal Data Law.
2.10. User — any visitor to the website https://gleefully-virtual-zinnia.tilda.ws/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons or making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunications networks, or providing access to personal data in any other manner.
2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a government authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data, making it impossible to restore its content in the personal data information system and/or destruction of physical media containing personal data.
3. Main Rights and Obligations of the Operator3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— in the event that the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with obligations established by the Personal Data Law and regulatory legal acts adopted pursuant thereto, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator shall:
— provide the personal data subject, upon request, with information concerning the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unlimited access to this Personal Data Processing Policy;
— take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions involving personal data;
— terminate the transfer (dissemination, provision, access) of personal data, terminate processing and destroy personal data in accordance with the procedure and in cases provided for by the Personal Data Law;
— perform other obligations provided for by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws;
— require the Operator to clarify, block or destroy their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purposes of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate its processing;
— appeal unlawful actions or omissions of the Operator in the processing of their personal data to the authorized body for the protection of the rights of personal data subjects or through judicial proceedings;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification, update or change to their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person's consent shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing5.1. Personal data shall be processed lawfully and fairly.
5.2. Processing of personal data shall be limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.
5.3. Databases containing personal data processed for purposes incompatible with each other may not be combined.
5.4. Only personal data that correspond to the purposes of their processing shall be processed.
5.5. The content and scope of processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, their accuracy, sufficiency and, where necessary, relevance to the purposes of processing shall be ensured. The Operator shall take the necessary measures and/or ensure that measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identification of the data subject for no longer than necessary to achieve the purposes of processing, unless the storage period is established by federal law, a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized once the purposes of processing have been achieved or when the need to achieve such purposes is no longer present, unless otherwise provided by federal law.
6. Purposes of Personal Data ProcessingPurpose of processing: informing the User by sending electronic messages.
Personal data:

• surname, first name, patronymic;
• email address;
• telephone numbers.

Legal grounds:

• statutory (founding) documents of the Operator.

Types of personal data processing:

• collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data.

7. Conditions for Processing Personal Data7.1. Processing of personal data is carried out with the consent of the personal data subject.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice and enforcement of a judicial act or an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. 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 entering into 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.
7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data to which an unlimited number of persons have been granted access by the personal data subject or at their request is processed as publicly available personal data.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for Collection, Storage, Transfer and Other Processing of Personal DataThe security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with applicable data protection legislation.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The User's personal data shall never, under any circumstances, be transferred to third parties, except where such transfer is required by applicable law or where the personal data subject has consented to the transfer of data to a third party for the performance of obligations under a civil-law contract.
8.3. If inaccuracies are identified in personal data, the User may update them independently by sending a notification to the Operator's email address info@gminternational.group with the subject line “Personal Data Update”.
8.4. The period of processing personal data is determined by the achievement of the purposes for which the data were collected, unless another period is established by contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator's email address info@gminternational.group with the subject line “Withdrawal of Consent to Personal Data Processing”.
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreements and Privacy Policies. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by a personal data subject on the transfer, processing or conditions of processing of personal data permitted for dissemination do not apply where personal data are processed in state, public or other public interests determined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures their confidentiality.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of processing, unless the storage period is established by federal law or contract.
8.9. Processing of personal data may be terminated upon achievement of the purposes of processing, expiration of the consent period, withdrawal of consent by the personal data subject, a request to terminate processing, or detection of unlawful processing.
9. List of Actions Performed by the Operator with Received Personal Data9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transmission of the information obtained through information and telecommunications networks or without such networks.
10. Cross-Border Transfer of Personal Data10.1. Before commencing activities involving cross-border transfer of personal data, the Operator shall notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out such cross-border transfer. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above notification, the Operator shall obtain the relevant information from the authorities of the foreign state, foreign individuals and foreign legal entities to which cross-border transfer of personal data is planned.
11. Confidentiality of Personal DataThe Operator and other persons who have access to personal data shall not disclose such data to third parties or disseminate them without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions12.1. The User may obtain any clarification concerning the processing of their personal data by contacting the Operator via email at info@gminternational.group.
12.2. Any changes to the Operator's Personal Data Processing Policy shall be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available online at: https://gleefully-virtual-zinnia.tilda.ws/.