Privacy Policy and Terms of Personal Data Processing

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 to ensure the security of personal data taken by OOO "SEM" (hereinafter — the Operator).
1.1. The Operator regards the observance of human and civil rights and freedoms in the processing of personal data — including the protection of the rights to privacy of personal life and to personal and family secrets — as its paramount objective and as a condition of carrying out its activities.
1.2. This Operator's policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://cosmotravel.co.

2. Key terms used in the Policy

2.1. Automated processing of personal data — the processing of personal data by means of computing technology.
2.2. Blocking of personal data — the temporary suspension of the processing of personal data (except where processing is necessary in order to correct personal data).
2.3. Website — a set of graphical and informational materials, together with computer programs and databases, ensuring their availability on the internet at the network address https://cosmotravel.co.
2.4. Personal data information system — a set of personal data contained in databases together with the information technologies and technical means ensuring their processing.
2.5. Depersonalisation of personal data — actions as a result of which it becomes impossible, without the use of additional information, to determine 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 in relation to personal data, including collection, recording, systematisation, accumulation, storage, correction (updating, amendment), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.
2.7. Operator — a state body, a municipal body, a legal entity or a natural person that, independently or jointly with others, organises and/or carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed in relation to personal data.
2.8. Personal data — any information relating directly or indirectly to a specified or identifiable User of the website https://cosmotravel.co.
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 for distribution in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://cosmotravel.co.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specified person or a specified group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data known to an unlimited number of persons, including publication of personal data in the mass media, placement on information and telecommunications networks, or the provision of access to personal data by any other means.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to a foreign state authority, or to a foreign natural person or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed such that the content of the personal data in the personal data information system cannot subsequently be restored, and/or as a result of which the material carriers of the personal data are destroyed.

3. Principal rights and obligations of the Operator

3.1. The Operator has the right:
— to receive from the personal data subject accurate information and/or documents containing personal data;
— where the personal data subject withdraws consent to the processing of personal data, or sends a request to cease the processing of personal data, to continue processing the personal data without the consent of the personal data subject where the grounds specified in the Personal Data Law are present;
— to determine independently the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations provided for by the Personal Data Law and by the regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or by 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;
— to organise the processing of personal data in the manner established by the applicable legislation of the Russian Federation;
— to respond to enquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— to report to the authorised body for the protection of the rights of personal data subjects, at that body's request, the necessary information within 10 days of the date of receipt of such a request;
— to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— to take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision or distribution of personal data, and against other unlawful actions in relation to personal data;
— to cease the transfer (distribution, provision, access) of personal data, to cease processing and to destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— to fulfil other obligations provided for by the Personal Data Law.

4. Principal 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;
— to require the Operator to correct their personal data, or to block or destroy them, where the personal data are incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take the measures provided for by law to protect their rights;
— to stipulate a requirement of prior consent to the processing of personal data for the purposes of promoting goods, works and services on the market;
— to withdraw consent to the processing of personal data, and to send a request to cease the processing of personal data;
— to appeal to the authorised body for the protection of the rights of personal data subjects, or through the courts, against unlawful acts or omissions of the Operator in the processing of their personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged:
— to provide the Operator with accurate information about themselves;
— to inform the Operator of any correction (updating, amendment) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or with information about another personal data subject without that subject's consent, bear liability 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 the 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 one another.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Excessiveness of the personal data processed in relation to the stated purposes of their processing is not permitted.
5.6. In processing personal data, the accuracy of the personal data, their sufficiency and, where necessary, their relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that such measures are taken to delete or correct incomplete or inaccurate data.
5.7. Personal data are stored in a form permitting identification of the personal data subject for no longer than the purposes of processing the personal data require, unless the storage 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. The personal data processed are destroyed or depersonalised upon achievement of the purposes of processing, or in the event that the need to achieve those purposes is lost, unless otherwise provided for by federal law.

6. Purposes of personal data processing

Purpose of processing — informing:

- the User by means of sending emails

Personal data:

- surname, first name, patronymic
- email address
- telephone numbers

Legal grounds:

- the Operator's constitutive (founding) documents

Types of personal data processing:

- Collection, recording, systematisation, accumulation, storage, destruction and depersonalisation of personal data
- Sending informational emails to the email address

7. Conditions for the processing of personal data

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 to carry out the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, for the execution of a judicial act, or of 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 the 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 thereby infringed.
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 that are subject to publication or mandatory disclosure in accordance with federal law.

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

The security of the personal data processed by the Operator is ensured through the implementation of the legal, organisational and technical measures necessary to comply in full with the requirements of the applicable legislation in the field of personal data protection.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases connected with compliance with the applicable legislation, 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. Should any inaccuracies in personal data be identified, the User may update them independently by sending the Operator a notification to the Operator's email address we@kosmotravel.ru marked "Updating of personal data".
8.4. The period of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or by applicable legislation.
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 we@kosmotravel.ru marked "Withdrawal of consent to the processing of personal data".
8.5. All information collected by third-party services, including payment systems, means of communication 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 aforementioned documents. The Operator bears no liability for the actions of third parties, including the service providers referred to in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (other than the provision of access), and on the processing or conditions of processing (other than obtaining access), of personal data permitted for distribution do not apply in cases of processing of personal data in the state, public and other public interests defined by the legislation of the Russian Federation.
8.7. In processing personal data, the Operator ensures the confidentiality of the personal data.
8.8. The Operator stores personal data in a form permitting identification of the personal data subject for no longer than the purposes of processing the personal data require, unless the storage 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. Grounds for ceasing the processing of personal data may include the achievement of the purposes of processing the personal data, the expiry of the personal data subject's consent, the withdrawal of consent by the personal data subject or a request to cease the processing of personal data, and also the identification 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, systematisation, accumulation, storage, correction (updating, amendment), extraction, use, transfer (distribution, provision, access), depersonalisation, 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 over 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 authorised body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator is obliged to obtain the relevant information from the foreign state authorities, foreign natural persons and foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other persons who have obtained 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 for by federal law.

12. Final provisions

12.1. The User may obtain any clarification on questions of interest concerning the processing of their personal data by contacting the Operator by email at we@kosmotravel.ru.
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://cosmotravel.co/en/privacy.