General provisions
1.1. This privacy policy of LLC «Aviaservice» in the field of processing and protection of personal data is drawn up in accordance with the requirements of the Federal Law of July 27, 2006. №152-FZ «On personal data» (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken at LLC «Air Service» (hereinafter referred to as – Airline, Operator).
1.2. The operator sets as its goal and condition for carrying out its activities the observance of the rights and freedoms of man and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
1.3. This Operator Policy regarding the processing of personal data (hereinafter – Policy) applies to all information that the Operator may obtain about website visitors https://aviaservice.aero.
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 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 that ensure their availability on the Internet at a network address https://aviaservice.aero.
2.4. Information system of personal data — a set of personal data contained in databases, and information technologies and technical means that ensure their processing.
2.5. Identification of personal data — actions as a result of which it is impossible to determine without the use of additional information whether personal data belongs to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator – government body, municipal body, legal entity or individual, independently or together with other persons organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or defined Website User https://aviaservice.aero.
2.9. Personal data authorized by the subject of personal data for distribution is personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data, permitted for distribution).
2.10. User – any website visitor https://aviaservice.aero.
2.11. Providing personal data – actions aimed at disclosing personal data to a certain person or a certain circle 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 the publication of personal data in the media, posting on 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 is destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and (or) material storage media of personal data is destroyed.
- Fundamental rights and obligations of the Operator
3.1. Operator entitled:
- receive from the subject of personal data reliable information and/or documents containing personal data;
- if the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The operator shall:
- provide the subject of personal data, at his request, with information relating to the processing of his personal data;
- organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
- communicate to the authorized body for the protection of the rights of personal data subjects, at the request of this body, the necessary information within 30 days from the date of receipt of such a request;
- publish or otherwise provide unrestricted access to this Policy with respect to the processing of personal data;
- take legal, organizational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
- stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
- perform other duties provided for by the Personal Data Law.
- Basic rights and obligations of personal data subjects
4.1. Personal data subjects shall be entitled to
- receive information regarding the processing of his personal data, except in cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, except in cases where there are legal grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
- require the operator to clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take measures provided by law to protect his rights;
- to put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
- revoke consent to 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 inactions of the Operator when processing his personal data;
- to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects shall:
- provide the Operator with reliable data about yourself;
- inform the Operator about clarification (updating, changing) of your personal data.
4.3. Persons who transferred false information about themselves to the Operator, or information about another subject of personal data without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.
- Volume and categories of personal data processed, categories of subjects of personal data
5.1. The operator processes personal data of the following categories of personal data subjects:
- airline clients;
- employees in an employment relationship with the Airline;
- persons previously in an employment relationship with the Airline;
- family members of Airline employees;
- candidates for employment with the Airline;
- natural persons in contractual and other civil law relations with the Airline;
- persons who have agreed to participate in marketing research;
- other persons who provided the Airline with their personal data or whose personal data was transferred to the Airline by a third party for processing.
5.2. The processing of personal data of persons who provided the Airline with their personal data or whose personal data was transferred by the Airline to a third party for processing on its behalf is carried out on the basis of federal laws and relevant agreements, agreements between the Airline and third parties.
5.3. The categories of personal data processed shall be defined separately for each purpose of processing and their list, and the scope shall not exceed that necessary for the implementation of the respective purposes of processing:
- for the purpose of fulfilling air transportation contracts, one of the parties to which is the subject of personal data - passenger (client), and providing additional services during air transportation;
- in order to manage the labor relations of the Airlines with employees in accordance with the legislation of the Russian Federation;
- for the purpose of searching and selecting, for the purpose of employing candidates to fill vacant positions;
- in order to control the physical access of Company employees to office premises;
- for the purpose of registration, issuance, cancellation and accounting of powers of attorney to provide interests and perform certain actions by individuals;
- for the purpose of maintaining publicly available directories of official contact information for employees;
- in order to manage relationships with counterparties of the Airline;
- for the purpose of maintaining accounting and tax records, as well as individual (personalized) accounting of individuals with the Airlines in accordance with the legislation of the Russian Federation;
- in order to provide employees with voluntary insurance programs, including health and accident insurance, as well as other types of insurance;
- for the purpose of maintaining the airline's corporate information portal;
- in order to ensure the correct operation of the site and publicly available resources.
5.4. The operator does not process special categories of personal data relating to race and nationality, political views, religious and philosophical beliefs, intimate life and biometric personal data, unless otherwise established by the legislation of the Russian Federation.
- List of information about personal data processed by the Operator.
6.1. Last name, first name, patronymic.
6.2. Date of birth.
6.3. Paul.
6.4. Identity document information;
6.5. Email address.
6.6. Phone numbers.
6.7. Technical parameters and other data for concluding a transaction.
6.8. The site also collects and processes anonymized data about visitors (including «cookie» files) using Internet statistics services (Yandex Metrics and Google Analytics and others).
6.9. The above data are further combined in the text of the Policy under the general concept of Personal Data.
6.10. The processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, and intimate life is not carried out by the Operator.
6.11. Processing of personal data authorized for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Personal Data Law is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Personal Data Law.
6.12. The User's consent to the processing of personal data permitted for distribution is formalized separately from other consents to the processing of his personal data. In this case, the conditions provided for, in particular, by Art. 10.1 of the Law on Personal Data. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
6.12.1 The User provides consent to the processing of personal data permitted for distribution to the Operator directly.
6.12.2 The operator is obliged, within no later than three working days from the date of receipt of the specified consent of the User, to publish information about the terms of processing, the existence of prohibitions and conditions for the processing by an unlimited number of persons of personal data permitted for distribution.
6.12.3. The transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution must be stopped at any time at the request of the subject of personal data. This requirement must include the last name, first name, patronymic (if any), contact information (phone number, email address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this requirement can only be processed by the Operator to whom it is sent.
6.12.4. Consent to the processing of personal data permitted for distribution shall cease to apply as soon as the Operator receives the requirement specified in paragraph. 5.9.3 of this Policy regarding the processing of personal data.
- Principles of processing personal data
7.1. The processing of personal data is carried out on a legal and fair basis.
7.2.The processing of personal data is limited to the achievement of specific, predetermined and legitimate objectives. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.
7.3.It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
7.4.Only personal data that meets the purposes of its processing is subject to processing.
7.5.The content and scope of the personal data processed correspond to the stated purposes of the processing. The redundancy of the personal data processed in relation to the stated purposes of their processing is not allowed.
7.6.When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data are ensured. The operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
7.7.The storage of personal data is carried out in a form that makes it possible to identify the subject of personal data no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, an agreement to which the beneficiary or guarantor is the subject of personal data. Processed personal data is destroyed or anonymized upon achievement of processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.
- Purposes of processing personal data
8.1. Purpose of processing the User's personal data:
- informing the User by sending emails;
- conclusion, execution and termination of civil contracts;
- providing access to the User to the services, information and/or materials contained on the website https://aviaservice.aero.
8.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User has the right to refuse to receive information messages at any time by sending an email to the Operator mail@aviaservice.aero marked «Refusal to notify new products and services and special offers».
8.3. Depersonalized User data, collected using Internet statistics services, serves to collect information about Users’ actions on the site, improve the quality of the site and its content.
- Legal basis for processing personal data
9.1. The legal grounds for processing personal data by the Operator are
9.2. Civil Code of the Russian Federation;
9.3. Federal Law "On Information, Information Technologies and Information Protection" dated July 27, 2006 N 149-FZ;
9.4. Federal Law of 02/09/2007 № 16-FZ «On transport security»;
- federal laws, other regulations in the field of personal data protection;
- consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution.
9.5. The Operator processes the User’s personal data only if it is filled out and/or sent by the User independently through special forms located on the site https://aviaservice.aero or sent to the Operator via email. By filling out the appropriate forms and/or sending his personal data to the Operator, the User expresses his consent to this Policy.
9.6. The Operator processes anonymized data about the User if this is allowed in the User’s browser settings (reserving «cookie» and using JavaScript technology are enabled).
9.7. The subject of personal data independently decides to provide his personal data and gives consent freely, by his will and in his own interest.
- Conditions for processing personal data
10.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
10.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law in order to carry out the functions, powers and responsibilities assigned by the legislation of the Russian Federation to the operator.
10.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
10.4. The processing of personal data is necessary for the execution of an agreement to which either the beneficiary or guarantor is a party, for which the subject of personal data is, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.
10.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
10.6. Personal data is processed, access to an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as – publicly available personal data).
10.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
- The procedure for collecting, storing, transmitting and other types of processing personal data
11.1. The security of personal data processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
11.2. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
11.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
11.4. If inaccuracies in personal data are detected, the User can update them independently by sending a notification to the Operator’s email address to the Operator mail@aviaservice.aeromarked «Updating personal data».
11.5. The period for processing personal data is determined by achieving the purposes for which personal data was collected, unless another period is provided for by the contract or current legislation.
The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address mail@aviaservice.aeromarked «Withdrawal of consent to the processing of personal data».
11.6. All information collected by third-party services, including payment systems, communications and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently familiarize himself with these documents in a timely manner. The operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
117. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions for processing (except for gaining access) personal data permitted for distribution, do not apply in cases of processing of personal data in state, public and other public interests, defined by the legislation of the Russian Federation.
11.8. When processing personal data, the operator ensures the confidentiality of personal data.
11.9. The operator stores personal data in a form that allows him to identify the subject of personal data no longer than the purposes of processing personal data require, if the period of storage of personal data is not established by federal law, an agreement to which the beneficiary or guarantor is the subject of personal data.
11.10. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data or the revocation of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.
- List of actions performed by the Operator with received personal data
12.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes and destroys personal data.
12.2. The operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
- Cross-border transfer of personal data
13.1. Before the start of cross-border transfer of personal data, the operator is obliged to make sure that the foreign state to whose territory it is planned to transfer personal data provides reliable protection of the rights of personal data subjects.
13.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can only be carried out if the subject of personal data has written consent to the cross-border transfer of his personal data and/or the execution of a contract to which the subject of personal data is a party.
- Privacy of personal data
14.1. The operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
- Final provisions
15.1. The User can obtain any clarification on issues of interest regarding the processing of his personal data by contacting the Operator via email mail@aviaservice.aero.
15.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is in effect indefinitely until it is replaced by a new version.
15.3. The current version of the Policy is freely available on the Internet at: https://aviaservice.aero.
