1. General provisions This Data processing policy defines the data processing procedure and data security measures taken inn-rate.com (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen in the processing of his data, including the protection of the rights to privacy, personal and family secrets.1.2. This Operator's data processing policy (hereinafter referred to as the Policy) applies to all information that the Operator can receive about website visitors inn-rate.com
2.1. Automated data processing – data processing using computer technology.
2.2. Data blocking – temporary termination of data processing (except in cases where processing is necessary to clarify the data).
2.3. Website - a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at a network address inn-rate.com
2.4. Information data system — a set of information technologies and technical means contained in databases and ensuring their processing.
2.5. Depersonalization of data — actions as a result of which it is impossible to determine, without the use of additional information, whether the data belongs to a specific User or another data subject.
2.6. Data processing – any action (operation) or set of actions (operations) performed with or without the use of automation tools with data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of data.
2.7. Operator – a legal entity, independently or jointly with other persons organizing and (or) performing data processing, as well as determining the purposes of data processing, the composition of data to be processed, actions (operations) performed with data.
2.8. Data – any information related directly or indirectly to a specific or identifiable User of the Website inn-rate.com
2.9. Data authorized by the data subject for distribution - data that an unlimited number of persons have access to by the data subject by giving consent to the processing of data authorized by the data subject for distribution in accordance with the procedure provided for by the Data Law (hereinafter - data authorized for distribution).
2.10. User – any visitor to the website inn-rate.com
2.11. Provision of data – actions aimed at disclosure of data to a certain person or a certain circle of persons.
2.12. Data dissemination – any actions aimed at disclosing data to an indefinite circle of persons (data transmission) or at familiarizing an unlimited circle of persons with data, including the publication of data in the media, posting in information and telecommunications networks or providing access to data in any other way.
2.13. Cross–border data transfer is the transfer of 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. Data destruction – any actions as a result of which data is permanently destroyed with the impossibility of further restoration of the data content in the data information system and (or) material data carriers are destroyed.
3.1. The Operator has the right to:
– receive reliable information and/or documents containing data from the data subject;
– if the data subject withdraws consent to data processing, the Operator has the right to continue data processing without the consent of the data subject if there are grounds specified in the Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Data Law or other federal laws.
3.2. The operator is obliged to:
– to provide the data subject, at his request, with information concerning the processing of his data;
– organize data processing in accordance with the procedure established by the current legislation;
– respond to requests and requests from data subjects and their legal representatives in accordance with the requirements of the Data Law;
– to report to the authorized body for the protection of the rights of 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 Data Processing Policy;
– take legal, organizational and technical measures to protect data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of data, as well as from other illegal actions with respect to data;
– stop transmitting (distributing, providing, accessing) data, stop processing and destroy data in the manner and cases provided for by the Data Law;
– perform other duties stipulated by the Data Law.
4.1. Data subjects have the right to:
– receive information concerning the processing of his data, except in cases provided for by federal laws. The information is provided to the data subject by the Operator in an accessible form, and it should not contain data related to other data subjects, except in cases where there are legitimate grounds for disclosure of such data. The list of information and the procedure for obtaining it is established by the Data Law;
– require the operator to clarify his data, block or destroy them if the 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 their rights;
– to put forward a condition of prior consent when processing data in order to promote goods, works and services on the market;
– to revoke consent to data processing;
– appeal to the authorized body for the protection of the rights of data subjects or in court against illegal actions or inaction of the Operator when processing his data;
– to exercise other rights provided for by law.
4.2. Data subjects are obliged to:
– provide the Operator with reliable data about yourself;
– inform the Operator about the clarification (update, change) of their data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another data subject without the consent of the latter, are liable in accordance with the law.
5.1. Legal entity.
5.2. Email address.
5.3. Phone numbers.
5.4. Taxpayer identification number, date of registration, details of the certificate of registration with the tax authority.
5.5. The address of the actual, legal location.
5.6. Income information.
5.7. Rates, prices, hotel loading, reviews.
5.8. Also on site is the collection and processing of anonymous data about visitors (including cookies) using Internet statistics (Yandex Metric and Google Analytics and others).
5.9. The above data, hereinafter referred to in the text of the Policy, are combined by the general concept of data.
5.10. Processing of special categories of data concerning race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.
5.11. Processing of data permitted for distribution from among the special categories of data specified in Part 1 of Article 10 of the Data Law is allowed if the prohibitions and conditions provided for in Article 10.1 of the Data Law are met.
5.12. The User's consent to the processing of data allowed for distribution is issued separately from other consents to the processing of his data. At the same time, the conditions stipulated, in particular, by Article 10.1 of the Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of data subjects.
5.12.1 Consent to the processing of data allowed for distribution, the User provides the Operator directly.
5.12.2 The Operator is obliged, no later than three working days from the date of receipt of the User's consent, to publish information on the processing conditions, on the existence of prohibitions and conditions for processing by an unlimited number of persons of data allowed for distribution.
5.12.3 The transfer (distribution, provision, access) of data authorized by the data subject for distribution must be terminated at any time at the request of the data subject. This requirement must include the surname, first name, patronymic (if any), contact information (phone number, e-mail address or postal address) of the data subject, as well as a list of data whose processing is subject to termination. The data specified in this request can only be processed by the Operator to whom it is sent.
5.12.4 Consent to the processing of data permitted for distribution ceases to be valid from the moment the Operator receives the request specified in clause 5.12.3 of this Data Processing Policy.
6.1. Data processing is carried out on a legal and fair basis.
6.2. Data processing is limited to achieving specific, predetermined and legitimate goals. Data processing incompatible with the purposes of data collection is not allowed.
6.3. It is not allowed to combine databases containing data that are processed for purposes incompatible with each other.
6.4. Only data that meets the purposes of their processing are subject to processing.
6.5. The content and volume of the processed data correspond to the stated purposes of processing. Redundancy of the processed data in relation to the stated purposes of their processing is not allowed.
6.6. Data processing ensures data accuracy, sufficiency, and, if necessary, relevance in relation to the purposes of data processing. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
6.7. Data storage is carried out in a form that allows determining the data subject, no longer than the data processing purposes require, unless the data storage period is established by federal law, an agreement to which the data subject is a party, beneficiary or guarantor. The processed data is destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
7.1. Purpose of User data processing:
– informing the User by sending emails;
– data analysis and processing for the provision of basic services by the Operator;
– providing the User with access to the services, information and/or materials contained on the website inn-rate.com ;
– for issuing tariff forecast data, rating evaluation on the Internet.
7.2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator privacy@inn-rate.com marked "Refusal of notifications about new products and services and special offers".
7.3. Depersonalized User data collected using Internet statistics services are used to collect information about User actions on the site, improve the quality of the site and its content.
8.1. The legal grounds for data processing by the Operator are:
– contracts concluded between the operator and the data subject;
– federal laws, other regulatory legal acts in the field of data protection;
– Users' consent to the processing of their data, to the processing of data allowed for distribution.
8.2. The Operator processes the User's data only if they are filled in and/or sent by the User independently through special forms located on the website inn-rate.com or sent to the Operator via e-mail. By filling out the appropriate forms and/or sending their data to the Operator, the User agrees with this Policy.
8.3. The Operator processes depersonalized data about the User if this is allowed in the User's browser settings (the saving of cookies and the use of JavaScript technology are enabled).
8.4. The data subject independently decides on the provision of his data and gives consent freely, of his own free will and in his own interest.
9.1. Data processing is carried out with the consent of the data subject to the processing of his data.
9.2. Data processing is necessary for the execution of a contract to which the data subject is a party or beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the data subject or a contract under which the data subject will be a beneficiary or guarantor.
9.3. Data processing 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 data subject are not violated.
9.4. Data processing is carried out, access of an unlimited number of persons to which is provided by the data subject or at his request (hereinafter referred to as publicly available data).
9.5. Data subject to publication or mandatory disclosure in accordance with federal law is processed.
The security of data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of data protection.
10.1. The Operator ensures the safety of the data and takes all possible measures to exclude access to the data of unauthorized persons.
10.2. The User's data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.
10.3. In case of inaccuracies in the data, the User can update them independently by sending a notification to the Operator to the Operator's email address privacy@inn-rate.com marked "Updating data".
10.4. The term of data processing is determined by the achievement of the purposes for which the data was collected, unless another term is provided for by the contract or current legislation. The User can withdraw his consent to data processing at any time by sending a notification to the Operator via e-mail to the Operator's e-mail address privacy@inn-rate.com marked "Withdrawal of consent to data processing".
10.5. All information collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or the User is obliged to familiarize themselves 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.
10.6. The prohibitions established by the data subject on the transfer (other than granting access), as well as on the processing or processing conditions (other than obtaining access) of data permitted for distribution, do not apply in cases of data processing in the state, public and other public interests defined by law.
10.7. The operator ensures data confidentiality during data processing.
10.8. The Operator stores data in a form that allows to identify the data subject, no longer than the data processing purposes require, unless the data storage period is established by federal law, an agreement to which the data subject is a party, beneficiary or guarantor.
10.9. The condition for termination of data processing may be the achievement of data processing objectives, expiration of the consent of the data subject or withdrawal of consent by the data subject, as well as the identification of illegal data processing.
11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys data.
11.2. The Operator performs automated data processing with or without receiving and/or transmitting the received information via information and telecommunication networks.
12.1. Prior to the start of the cross-border data transfer, the Operator is obliged to make sure that the foreign state to whose territory the data transfer is supposed to be carried out provides reliable protection of the rights of data subjects.
12.2. Cross-border data transfer on the territory of foreign states that do not meet the above requirements may be carried out only if there is written consent of the data subject to the cross-border transfer of his data and/or execution of the contract to which the data subject is a party.
The operator and other persons who have gained access to the data are obliged not to disclose to third parties and not to distribute the data without the consent of the data subject, unless otherwise provided by federal law.
14.1. The User can get any clarifications on issues of interest concerning the processing of his data by contacting the Operator via e-mail privacy@inn-rate.com
14.2. This document will reflect any changes to the Operator's data processing policy. The policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at inn-rate.com/privacy