Personal Data Processing Policy

This is a translation for reference. The Russian version of the policy is the legally binding one.

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by Individual Entrepreneur Lev Borisovich Solenov (hereinafter — the Operator).

1.1. The Operator considers respect for human and civil rights and freedoms when processing personal data, including protection of the rights to privacy and to personal and family secrets, to be the most important goal and condition of its activities.

1.2. This Operator policy on personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://r-u.ru.

2. Key terms used in the Policy

2.1. Automated processing of personal data — processing of personal data by means of computer technology.

2.2. Blocking of personal data — temporary suspension of personal data processing (except 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://r-u.ru.

2.4. Personal data information system — a set of personal data contained in databases together with the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions as a result of which it becomes impossible, without the use of additional information, to establish that personal data belong to a particular User or other personal data subject.

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), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of the personal data to be processed, and the 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://r-u.ru.

2.9. Personal data permitted by the personal data subject for distribution — personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided for by the Personal Data Law (hereinafter — personal data permitted for distribution).

2.10. User — any visitor to the website https://r-u.ru.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publication of personal data in the mass media, posting on information and telecommunications 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 a foreign state authority, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are irrevocably destroyed with no possibility of further recovery of the content of the personal data in the personal data information system, and/or as a result of which the physical media of the personal data are destroyed.

3. Key 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;
  • if the personal data subject withdraws consent to the processing of personal data, and also if a request to stop the processing of personal data is sent, the Operator has the right to continue processing personal data without the consent of the personal data subject where the grounds specified in the Personal Data Law are present;
  • independently determine the composition and list of measures necessary and sufficient to ensure fulfilment of the obligations provided for 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.

3.2. The Operator is obliged to:

  • provide the personal data subject, at their request, with information concerning 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 requests and enquiries from 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 the rights of personal data subjects, at the request of that body, the necessary information within 10 days from the date of receipt of such a request;
  • publish or otherwise provide unrestricted access to this Policy on personal data processing;
  • take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision and distribution of personal data, as well as against other unlawful actions in relation to personal data;
  • stop the transfer (distribution, provision, access) of personal data, stop the processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
  • fulfil other obligations provided for by the Personal Data Law.

4. Key rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

  • receive information concerning the processing of their personal data, except in the cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • require the operator to clarify their personal data, to block or destroy it if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or are not necessary for the stated purpose of processing, and also to take the measures provided for by law to protect their rights;
  • put forward a condition of prior consent to 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 also to send a request to stop the processing of personal data;
  • appeal to the authorized body for the protection of the rights of personal data subjects, or in court, against unlawful actions or omissions of the Operator in the processing of their personal data;
  • exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

  • provide the Operator with reliable data about themselves;
  • inform the Operator about the clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter’s consent, bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data are processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.

5.3. It is not permitted to combine databases containing personal data whose processing is carried out for purposes that are 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 scope of the personal data processed correspond to the stated purposes of processing. Redundancy of the personal data processed in relation to the stated purposes of their processing is not permitted.

5.6. When processing personal data, the accuracy of the personal data, their sufficiency and, where necessary, their relevance to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data are stored in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period for the personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achievement of the purposes of processing, or if the need to achieve those purposes is lost, unless otherwise provided by federal law.

6. Purposes of personal data processing

Purpose of processing

providing the User with access to the services, information and/or materials contained on the website

Personal data

surname, first name, patronymic

email address

telephone numbers

Legal grounds

Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”, as well as other federal laws and subordinate acts of the Russian Federation that determine the cases and specifics of personal data processing and of ensuring the security and confidentiality of such information.

Types of personal data processing

Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

7. Conditions for personal data processing

7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.

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, and for the exercise of the functions, powers and duties assigned to the operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

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, and also for the conclusion of a contract at the initiative of the personal data subject or of a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or of third parties, or for the achievement of socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing is carried out of personal data to which access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter — publicly available personal data).

7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for the collection, storage, transfer and other types of personal data processing

The security of the personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary for full compliance with the requirements of the current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law, or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.

8.3. If inaccuracies are found in personal data, the User may update them independently by sending the Operator a notification to the Operator’s email address office@r-u.travel marked “Updating of personal data”.

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or by applicable law. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notification by email to the Operator’s email address office@r-u.travel marked “Withdrawal of consent to the processing of personal data”.

8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. Prohibitions established by the personal data subject on the transfer (other than the provision of access), as well as on the processing or the conditions of processing (other than obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless the retention period for the personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.

8.9. A condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, the expiry of the consent of the personal data subject, the withdrawal of consent by the personal data subject or a request to stop 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 the personal data received

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the information obtained via information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of the intention to carry out personal data processing).

10.2. Before submitting the above notification, the Operator is obliged to obtain the relevant information from the authorities of the foreign state and from the foreign individuals and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other persons who have gained access to personal data are obliged not to disclose personal data 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 on questions of interest concerning the processing of their personal data by contacting the Operator by email at office@r-u.travel.

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.

12.3. The current version of the Policy is freely available on the internet at https://r-u.ru/privacy.