Pilgrim Tours Privacy Policy

1. General Provisions
This Privacy Policy is prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by OOO "Pilgrim-Tours" (hereinafter — the Operator).
1.1. The Operator's paramount goal and condition for carrying out its activities is to respect 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 Privacy Policy (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://pilgrim-tours.ru/.

2. Basic Terms 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 suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the internet at the network address https://pilgrim-tours.ru/.
2.4. Personal data information system — a set of personal data contained in databases and 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 to determine, without additional information, the ownership of personal data 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 with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information directly or indirectly related to a specific or identifiable User of the website https://pilgrim-tours.ru/.
2.9. Personal data permitted by the subject of personal data for distribution — personal data to which an unlimited circle of persons has been granted access 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 Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://pilgrim-tours.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or specific circle of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the mass media, placement in 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 permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or the physical media of personal data are destroyed.

3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right:
— to receive accurate information and/or documents containing personal data from the subject of personal data;
— in the event of revocation by the subject of personal data of consent to the processing of personal data, as well as sending a request to terminate 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 Personal Data Law;
— to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and 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 subject of personal data, upon their request, with information relating to the processing of their personal data;
— to organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— to respond to requests and inquiries of subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— to report to the authorized body for the protection of the rights of subjects of personal data, upon request of this body, the necessary information within 10 days from the date of receipt of such request;
— to publish or otherwise provide unrestricted access to this Privacy Policy;
— to take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
— to cease the transfer (distribution, provision, access) of personal data, terminate processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— to fulfill other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right:
— to receive information relating to the processing of their 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 must not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— to demand from the Operator clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— to impose a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
— to revoke consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;
— to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against unlawful actions or inaction 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. Subjects of personal data are obliged:
— to provide the Operator with accurate data about themselves;
— to inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves, or information about another subject of personal data without the latter's consent, are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing
5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not permitted.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized upon achievement of the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing


7. Conditions for Processing Personal Data
7.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers and duties assigned by the legislation of the Russian Federation to the Operator.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party, or a beneficiary or guarantor under which the subject of personal data is a party, as well as for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. 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.
7.6. Processing of personal data is carried out, access to which is provided by the subject of personal data to an unlimited circle of persons or at their request (hereinafter — publicly available personal data).
7.7. Processing of personal data is carried out, subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer and Other Types of Processing of Personal Data
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 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 unauthorized persons from accessing 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 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 law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator's email address piligrimtourscom@yandex.ru with the subject line "Personal data update".
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is provided for by the contract or current legislation. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address piligrimtourscom@yandex.ru with the subject line "Withdrawal of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, communication means 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 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 clause.
8.6. Prohibitions established by the subject of personal data on transfer (except for providing access), as well as on processing or conditions of processing (except for 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 allows identifying the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.
8.9. The 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, the withdrawal of consent by the subject of personal data or a request to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, changing), 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 transmission of the received information via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities on cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out 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 above notification, the Operator is obliged to obtain relevant information from foreign state authorities, foreign individuals, foreign legal entities to whom 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 to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

12. Final Provisions
12.1. The User may obtain any clarification on issues of interest regarding the processing of their personal data by contacting the Operator via email at piligrimtourscom@yandex.ru.
12.2. This document will reflect any changes to the Operator's personal data processing policy. 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://pilgrim-tours.ru/en-policy.

12.4. Special Provisions for Foreign Nationals
The Operator operates within the legal framework of the Russian Federation. For citizens and residents of foreign jurisdictions, the Operator declares the following:
The Operator is committed to processing personal data in accordance with the requirements of Russian legislation, including Federal Law No. 152-FZ "On Personal Data."
If you are subject to the laws of a foreign jurisdiction and have individual requirements, restrictions, or specific preferences regarding the processing of your personal data that differ from or supplement the provisions of this Policy, please notify the Operator explicitly upon first contact. The Operator will make reasonable efforts to accommodate any proposed data processing protocol or data protection framework requested by a foreign national, provided that such accommodation does not violate the legislation of the Russian Federation or the Operator's legal obligations under Russian law.

For any questions regarding the application of this clause, please contact the Operator via email at pilgrim-tours@yandex.ru