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Agreement on Confidentiality

Conditions of LLC «Sochi Service» Handling (MSRN 1152366010829; address: 354000, office 10.3, house 11, Orjonikidze street, Sochi, Russian Federation,) of site users` data

Filling in various application forms in the site for getting information, sending service inquiries, subscriptions, getting tickets from The SOCHI CLUB Concierge Service  (further – «Company»), as well as realizing any actions to use Company and Site (www.sochi-club.com) services (further – «Company»), User gives his unconditional consent to the processing of all personal data (including, but not limiting: SNP, birth date and place, ID document data, mail address, telephone number, bank accounts` data and cards, and so on), that User points on filling in the forms in the Site. The processing of User`s personal data is done to realize the requirements, to supply with services, to make User use the Site functional, including the analysis of the data that will help to improve the service and the Site functional quality. Herewith, User gives his agreement on processing his personal data, including (not limiting), collection, registration, systematization, accumulation, keeping, refinement (refreshment, modification), extraction, use, passing (spreading, provision, access), including trans-boundary, to the third person, depersonalization, blocking,  deleting, liquidation, and doing any other actions to User`s personal data, in accordance with the Federal Legislation. The time, valuable for processing User`s personal data is 15 (fifteen) years. Besides, User`s agreement can be withdrawn. To withdraw the agreement, User should send his written application by LLC «Sochi Service» address (354000, office 10.3, house 11, Orjonikidze Street, Sochi, Russian Federation). Filling in various forms in the Company site, User gives also his agreement on audio-registration of the phone talks with Company representative,  sending information to the e-mail address given by him, or sending SMS-messages on mobile phone number, to get the services and be informed about new possibilities, offers and events, organized by Company. User personal data, contained in the various forms, filled by him in the Site, is kept and processed, in regard with the conditions of the Personal Data Processing Policy.

LLC «Sochi Service» Policy on Personal Data Processing

  1. General Conditions

The policy of LLC «Sochi Service» (further - Society) in regard with the personal data (further – Society Policy) is worked out in conformity with the demands of Federal law №152-FЗ from 27 July of 2006 «About Personal Data» (further FЗ №152)  other normative – legal acts and is implemented with respect to all personal data, processed  by Society in the process of realization of its activities.

The Society Policy is worked to inform the people whose personal data is kept by Society (further – the subjects of the personal data), about the list of processed personal data, goals and means of processing of the given data, security measures, and other information, connected with processing of the personal data of the pointed subjects.

The processing of personal data is worked out by Society with the consent of the subject, to work out in any allowing form, confirming the fact of getting the new form if no other way is established by Federal Law. 

 Society reserves the right to make the necessary changes in the Society Policy, including changes, connected with the acting Law of Russian Federation.

  1. The List of Processed Personal Data

Personal data supposes any information, connected directly or indirectly with definite or determined physical person (the personal data subject).

Within the framework of its activity, Society can collect and process the following personal data:

- Surname, Name, Patronymic;

- Sex;

- Birth Date and Birth Place;

-  ID Document Data;

- E-Mail address;

- Phone Number;

- Bank Name and Requisites, Current Account Number;

- Bank Card Number.

With regard to the employees of Society additional information about education, foreign languages, work activity, work encouragement,  penalties and rewards; family status, family members (their number and activity), passport data, telephone number; address information, information on production activities; information about  benefits and guarantees, attestation and characteristics, information about professional education, professional re-preparation, information about income, property and obligations on property; about preventive medical investigations, about partial or temporal incapacity for work, workers` efficiency mark.

The list above is not final, it can include some changes.

  1. The Principal of Personal Data Processing

Society follows the established norms, requirements and procedures of the legislation in connection with the processing of personal data, and is led by the principles, given below:

Processing of personal data is done by Society on legal and just basis.

Processing of personal data is limited by getting concrete, predetermined and legal goals. It is not allowed to process personal data, incompatible with the reasons of collection of personal data.

It is not allowed to connect databases, with personal data, the processing of which is realized for goals, incompatible with each other. Only personal data is subject that meet the goals of processing.

Society ensures the correspondence of the content and volume of the personal data to the determined goals and processing.

In processing personal data precision, necessary volume, and, if it is necessary, the actuality of personal data are provided for the goals of processing. Society takes all the necessary measures either for deleting or précising incomplete or imprecise data.

The keeping of personal data is done in form that allows to determine the subject of personal data no longer than it is needed for processing of personal data.  The processed personal data is either liquidated or depersonalized for impossibility to correlate with certain subject of personal data after reaching the goals of processing, or in case it is no longer necessary to reach these goals and if no other way is foreseen by Federal Law or contract, the beneficiary or guarantor of which is the subject of personal data.

Society and other persons with the access to personal data, take measures to prevent disclosure and spreading of personal data, in cases, when the subject of personal data did not leave his agreement for such disclosure and if no other variant is provided by Federal Law.

  1. The Goals and Conditions of Personal Data Processing

Society realizes collection and procession of personal data of the subject:

- to supply the subject with services provided for personal data;

- to process inquiries of the subject for personal data;

- to analyze personal data of the subject for service improvement.

The processing of personal data by Society is allowed particularly in the following cases:

- the subject of the personal data gives his agreement for processing;

- the processing is necessary for following the contract, the side, beneficiary or guarantor of which is the subject of the personal data, and for signing  a contract by the initiative of the subject or the agreement, by which the subject will become the beneficiary or the guarantor;

- the processing of personal data is necessary for realizing and fulfilling the functions, powers and responsibilities, entrusted Society by Russian Federation;

- in other cases, provided by legislation.

  1. People, Accessed to Personal Data

The access to personal data is for those employees of Society who need this information to carry on their professional duties. The list of positions, accessed to personal data, is confirmed by the order of Society.

In case, Society is supplied by services of legal or physical persons,  on the basis of signed agreements (or other reasons), hence obtaining the right to make an access to personal data, it should sign an agreement on non-disclosure of personal information, then the corresponding personal data are given only in case there is either a signed agreement between corresponding persons on non-disclosure of confidential information or there is a position of confidentiality in the agreements, mentioned above.

  1. The Ways of Personal Data Processing by Society

Within the frameworks of Society Policy processing of personal data presumes any action (operation) or complex actions (operations), done both with the use of automatized means and without it, including collection, registration, systematization, accumulation, keeping, precision (renovation, modification), extraction, use, passing (spreading, supplying, access), depersonalization, blocking, deleting, abolition of personal data.

Society cannot make decisions that can either cause legal effects in relation to the subject of personal data or affect his rights or legal interests on basis of exceptionally automatized procession of personal data.

  1. Processing Time For Personal Data

The time for processing personal data is determined, coming out of the goals of the processing in accordance with requirements of legislation.

Personal data, processed in information systems of Society, is liquidated within thirty days either after reaching the goal of personal data processing or from the moment of stopping the processing or depersonalization, if there are no other ways, established by law.  

  1. Measures Taken by Society To Provide The Security of Personal Data During Their Processing

Society itself decides the type and the list of measures for realization of law positions and for security of personal data during their processing.  Particularly, Society:

- supports the realization of inner control of the correspondence of personal data processing with positions FЗ №152 and taken legal acts in accordance with normative legal acts, requirements on personal data security, Society Policy in relation to personal data processing,  local acts of Society;

- realizes the acknowledgement of employees, that do the processing of personal data with the positions of The RF Legislation about personal data, including the requirements for personal data security, documents,  that decide the operator policy, local acts on issues of personal data processing;

- realizes the definition of security threats during the processing of personal data in information systems of personal data;

- realizes the implementation of organizational and technical measures on supporting personal data security during their processing in information systems of personal data, using the procedure of evaluation of correspondence of means of information security, passed in the determined order;

- establishes access rules to personal data, processed in the system of personal data, and providing with registration and accounting of all the actions with personal data in the information system of personal data;

- realizes permanent control of the security level of personal data;

- takes other measures, directed to the supporting of personal data security during their processing.