Policy on Personal Data Processing

1.    General Provisions  

This personal data processing policy is compiled in accordance with the requirements of the Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law), and it defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC "Viraton" (hereinafter referred to as the Operator). 

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets. 

1.2. This policy of the Operator on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://flight-market.com. 

2.    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 personal data processing (except in cases where processing is necessary to clarify personal data). 

2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address https://flight-market.com. 

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. Anonymization of personal data — actions resulting in the impossibility of determining the affiliation of personal data to a specific User or other subject of personal data without using additional information. 

2.6. Processing of personal data — any action (operation) or a set of actions (operations) performed with personal data, with or without the use of automation tools, 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 — a state body, municipal body, legal or physical person, which independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, 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 determined or determinable User of the website https://flight-market.com. 

2.9. Personal data allowed by the personal data subject for dissemination — personal data to which an unlimited range of persons has access, provided by the personal data subject by giving consent to the processing of personal data allowed for dissemination in accordance with the procedures established by the Personal Data Law (hereinafter referred to as personal data allowed for dissemination). 

2.10. User — any visitor to the website https://flight-market.com. 

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 circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, the placement in information and telecommunication networks, or the provision of access to personal data in any other way. 

2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to the authority of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions resulting in the permanent destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or the destruction of the physical media on which the personal data is stored.

3.    Main Rights and Obligations of the Operator  

1.    The Operator has the right to: 

- Receive accurate information and/or documents containing personal data from the personal data subject; 

- In the event that the personal data subject withdraws their consent for personal data processing or sends a request demanding the cessation of personal data processing, the Operator reserves the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law; 

- Independently determine the composition and list of measures necessary and sufficient to fulfill duties provided by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise specified by the Personal Data Law or other federal laws. 

2.    The Operator is obliged to: 

- Provide the personal data subject, upon their request, with information regarding the processing of their personal data; 

- Organize the processing of personal data in accordance with the procedures 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 with necessary information upon request from this body within 10 days from the date of receipt of such a 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, modification, blocking, copying, provision, dissemination, as well as from other illegal actions regarding personal data; 

- Cease the transmission (dissemination, provision, access) of personal data, halt processing, and destroy personal data in the manner and cases stipulated by the Personal Data Law; 

- Fulfill other obligations stipulated by the Personal Data Law. 

4.    Main Rights and Obligations of Personal Data Subjects  

1.    Personal data subjects have the right to: 

- Receive information regarding the processing of their personal data, except in 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 related to other personal data subjects unless 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; 

- Demand that the Operator clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, obtained unlawfully, or is not necessary for the stated purposes of processing, as well as take legal measures to protect their rights; 

- Set a condition of prior consent for the processing of personal data for the purposes of promoting goods, works, and services in the market; 

- Withdraw consent for personal data processing and send a demand for the cessation of personal data processing;

- To exercise other rights provided by the legislation of the Russian Federation. 

2.    Obligations of Personal Data Subjects 

- Provide the Operator with accurate information about themselves; 

- Inform the Operator about clarifications (updates, changes) to their personal data. 

3.    Responsibility for Providing Incorrect Data 

Persons who provide the Operator with false information about themselves, or information about another personal data subject without their consent, are liable in accordance with the legislation of the Russian Federation. 

5.    Principles of Personal Data Processing  

1.    Personal data processing is carried out on a lawful and fair basis. 
2.    Personal data processing is limited to achieving specific, predetermined, and lawful purposes. The processing of personal data that is incompatible with the purposes of collecting personal data is not allowed. 
3.    Combining databases containing personal data processed for purposes that are incompatible with each other is not permitted. 
4.    Only personal data that meets the purposes of their processing is subject to processing. 
5.    The content and volume of processed personal data correspond to the stated purposes of processing. Excessive personal data processed in relation to the purposes of its processing is not permitted. 
6.    The accuracy, sufficiency, and, where necessary, relevance of personal data are ensured in relation to the purposes of their processing. The Operator takes necessary measures and/or ensures that measures are taken to delete or clarify incomplete or inaccurate data. 
7.    Personal data is stored in a form that allows determining the personal data subject for no longer than required by the purposes of personal data processing unless a storage period is established by federal law, the agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or if the need to achieve these 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 available on the website. 

Personal data types: 

- Surname, first name, patronymic (if applicable); 

- Phone numbers. 

Legal grounds: 

- Federal Law "On Information, Information Technologies and Protection of Information" of 27.07.2006 No. 149-FZ. 

Types of personal data processing: 

- Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data. 

7.    Conditions for Personal Data Processing

7.1. Processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data. 

7.2. Personal data processing is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to perform functions, powers, and duties assigned to the operator under the legislation of the Russian Federation. 

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

7.4. Personal data processing 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 on the initiative of the personal data subject or a contract where the personal data subject will act as a beneficiary or guarantor. 

7.5. Personal data processing is necessary to implement 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 personal data subject are not violated.

7.6. The processing of personal data is carried out when access to such data has been provided by the subject of personal data to an unlimited number of individuals or at their request (hereinafter referred to as publicly available personal data). 

7.7. The processing of personal data is carried out when such data is 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 personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.

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

8.2. The user's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the subject of personal data has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.

8.3. In case of detected inaccuracies in personal data, the User can update them independently by sending a notice to the Operator at the Operator's email address ops@flight-market.com with the subject "Personal Data Update."

8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless otherwise specified by contract or current legislation. The user may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator via email at ops@flight-market.com with the subject "Withdrawal of Consent for Personal Data Processing."

8.5. All information collected by third-party services, including payment systems, communications service providers, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this section.

8.6. Any prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or conditions of processing (except for granting access) of personal data permitted for dissemination, do not apply in cases where personal data is processed in state, public, and other public interests as defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data during its processing.

8.8. The Operator stores personal data in a form that allows identifying the subject of the personal data for no longer than the purposes for which the personal data is being processed require, unless a storage period for personal data is established by federal law, a contract, or if the data subject is a party, beneficiary, or guarantor under such a contract.

8.9. The processing of personal data may be terminated upon the achievement of the purposes of personal data processing, the expiration of the consent period of the data subject, the withdrawal of consent by the data subject, a request by the data subject to cease personal data processing, or the detection of unlawful processing of personal data.

9.    List of Actions Performed by the Operator with Received Personal Data

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

9.2. The Operator conducts automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without such means.

10.           Cross-border Transfer of Personal Data

10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects about their intention to carry out such a transfer (this notification is sent separately from the notification of the intention to process personal data).

10.2. Prior to submitting the aforementioned notification, the Operator is required to obtain appropriate information from the foreign state authorities, foreign individuals, or 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 obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.

12.           Final Provisions  

12.1. The User can obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator via email at ops@flight-market.com. 

12.2. Any changes to the Operator's policy on the processing of personal data will be reflected in this document. The policy remains in effect indefinitely until replaced by a new version. 

12.3. The current version of the Policy is freely available on the Internet at https://flight-market.com/privacy/.

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