This is an English translation provided for your convenience. The legally binding version of this Personal Data Processing Policy is the Russian one; in case of any discrepancy, the Russian text prevails.
1. General provisions
1.1. This Personal Data Processing Policy (the “Policy”) has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Personal Data Law”).
1.2. The operator processing personal data is the legal entity White Snow LLC (Russian: “Santa” LLC, TIN 6501090158, OGRN 1026500544400, registered address: 3 Detskaya St., Yuzhno-Sakhalinsk, Sakhalin Region, 693020), hereinafter the “Operator”.
1.3. The Operator’s most important goal is to respect human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and to personal and family confidentiality.
1.4. This Policy applies to all information that the Operator may obtain about visitors (“Users”) of the website https://ws65.ru/ (the “Site”).
1.5. This Policy is a publicly available document and is permanently accessible at https://ws65.ru/privacy.
2. Key terms used in the Policy
2.1. Personal Data Law – Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
2.2. Personal data – any information relating directly or indirectly to an identified or identifiable natural person (the data subject).
2.3. Data subject – the natural person (User) to whom the processed personal data relates.
2.4. Processing of personal data – any action or set of actions with personal data, including collection, recording, systematisation, accumulation, storage, updating, retrieval, use, transfer (distribution, provision, access), de-personalisation, blocking, deletion and destruction.
2.5. Site – the Operator’s website located at https://ws65.ru/.
2.6. Automated processing of personal data – processing of personal data using computing technology.
2.7. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state.
2.8. Destruction of personal data – actions that make it impossible to restore the content of personal data in an information system and/or that destroy the physical media of personal data.
3. Purposes, legal grounds and periods of personal data processing
3.1. The Operator processes a User’s personal data only where at least one of the following conditions is met:
- processing is carried out with the User’s consent;
- processing is necessary to perform a contract to which the User is a party;
- processing is necessary to exercise the rights and legitimate interests of the Operator.
3.2. The Operator processes personal data for the following purposes:
| Purpose of processing | Categories of personal data processed | Legal ground | Processing and storage period |
|---|---|---|---|
| Performance of a contract and handling of requests (room booking, provision of hotel services, rental) | Full name, email, phone number | Performance of a contract (clause 5, part 1, art. 6 of the Personal Data Law) | Term of the contract + 3 years after its completion (limitation period) |
| Providing access to services and information on the Site (feedback) | Email, cookies, phone number | Performance of a contract (the User Agreement, clause 5, part 1, art. 6 of the Personal Data Law) | For the duration of the use of the services |
| Sending marketing and informational mailings | Name, email | Separate consent of the User (clause 1, part 1, art. 6 of the Personal Data Law) | Until the User withdraws consent |
| Collecting analytics to improve the Site | De-personalised data: IP address, cookies, browser type, time on site | Separate consent of the User (obtained via the cookie banner) | 1 year from the moment consent is given |
4. Procedure for obtaining consent
4.1. The User’s consent to the processing of personal data is specific, informed and conscious, and is given by ticking a dedicated checkbox under the data-collection forms on the Site.
4.2. The text under the checkbox explains to the User which data and for what specific purpose they are consenting to be processed.
4.3. Consent to receive advertising mailings and consent to the processing of cookies for analytics are given separately from consent to perform a contract.
4.4. By performing these active actions, the User confirms that they have read and agree to this Policy.
5. Procedure for collection, storage, transfer and other processing of personal data
5.1. The security of personal data is ensured through the implementation of legal, organisational and technical measures necessary to comply with the law.
5.2. The Operator ensures the safekeeping of personal data and takes measures to prevent access by unauthorised persons.
5.3. The Operator may engage third parties to process personal data in order to achieve the purposes set out in section 3. Such parties include:
- Web analytics services (Yandex LLC for the Yandex.Metrica service) for collecting analytical data.
Any such engagement is carried out on the basis of a contract obliging the third party to maintain the confidentiality and security of personal data.
5.4. If inaccuracies in personal data are discovered, the User may update them by sending a notice to the Operator’s email admin@ws65.ru marked “Updating personal data”.
5.5. The User may withdraw their consent to the processing of personal data at any time by sending a notice to admin@ws65.ru marked “Withdrawal of consent”. After receiving the withdrawal, the Operator stops processing and destroys the personal data within a period not exceeding 30 days.
6. Use of cookies
6.1. To improve the Site’s operation, the Operator uses cookies – small text files that a web server places on the User’s device.
6.2. We use the following categories of cookies:
- Strictly necessary: required for the basic functioning of and navigation on the Site. They cannot be disabled.
- Analytics/statistics: help us understand how Users interact with the Site by collecting and reporting information anonymously. Enabled only with the User’s consent.
- Marketing: used to track visitors across websites in order to show relevant advertising. Enabled only with the User’s consent.
6.3. On a first visit to the Site, the User is invited to give consent to the use of cookies or to refuse them (except strictly necessary ones) via a dedicated banner.
7. Cross-border transfer of personal data
7.1. Before carrying out a cross-border transfer of personal data, the Operator must make sure that the foreign state to whose territory the data is to be transferred provides reliable protection of the rights of data subjects.
7.2. A cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only where there is written consent from the data subject to the cross-border transfer of their personal data and/or for the performance of a contract to which the data subject is a party.
8. Final provisions
8.1. The User may obtain any clarifications regarding the processing of their personal data by contacting the Operator by email at admin@ws65.ru.
8.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in force until it is replaced by a new version.
8.3. The person responsible for organising the processing of personal data at the company is Director Ivan Vitalyevich Kazyonnov.
8.4. The current version of the Policy is freely available on the Internet at https://ws65.ru/privacy.