Continent Business Hotel Personal Data Processing and Protection Policy

1. General rules

• 1.1. Petr Demchenko, an individual entrepreneur, processes personal data on a legal basis.
• 1.2. Processing of personal data is carried out in accordance with the Constitution of the Russian Federation, the Federal Law “On Personal Data” N 152-ФЗ dated 27.07.2006, the Decree of the Government of the Russian Federation No 687 dated September 15, 2008 and No 1119 dated 01.11.2012, as well as other regulations.
• 1.3. Main concepts used in the Policy:
  • Hotel — Individual entrepreneur P.V. Demchenko providing hotel services to the client;
  • Client — a private entity, a consumer of hotel services, a subject of personal data;
  • Hotel services — the Hotel's actions to accommodate Clients in the accommodation facility, as well as other activities regarding accommodation and stay, which include basic and additional services provided to the Client;
  • Operator — a person who alone or together with other persons organizes and (or) carries out processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data subject to processing, actions (operations) performed with personal data;
  • Personal Data — information stored in any format relating to a private entity (subject of personal data) defined or determined on the basis of such information, which by itself or in combination with other information at the Hotel's disposal allows to identify the Client's identity;
  • 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 (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
  • Personal data information system — a combination of information technologies and technical means contained in personal data bases and ensuring their processing;
  • Personal data sharing — actions aimed at providing personal data to a certain person or a certain number of people;
  • International data transfer — transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign private entity or a foreign legal entity;
  • Use of personal data — actions (operations) with personal data performed by the operator in order to make decisions or perform other actions that give rise to legal consequences in respect of the personal data subject or other persons or otherwise affect the rights and freedoms of the personal data subject or other people;

2. Client’s personal data processing policy

• 2.1. Personal data of clients may be processed for the following purposes:
  • booking rooms in the Hotel
  • preparation and execution of the contract on provision of accommodation or temporary accommodation services in the Hotel.
• 2.2. The Operator is not allowed to process personal data other than for the specified purposes.
• 2.3. Personal data may not be used for the purpose of causing property and moral damage to citizens, hindering the exercising of rights and freedoms of citizens of the Russian Federation.

3. Client’s personal data processing policy

• 3.1. The scope and content of processed personal data strictly corresponds to the specified processing purposes and is not excessive in relation to the processing purposes.
• 3.2. The Clients' personal data collected and processed by the Hotel shall include:
  • Full name
  • Date and place of birth
  • ID data
  • Registration address (place of residence)
  • Contact phone number
  • Information about the workplace.
• 3.3. Hotel's personnel shall receive personal data upon the written consent of the Client.
• 3.4. The Hotel's employees have the right to verify the accuracy and relevance of the personal data provided.
• 3.5. When using the booking service, the following information will be collected: Client's full name, telephone number and e-mail address. These data are used to clearly identify the reservation once in order to provide the hotel service.

4. Client’s personal data processing policy

• 4.1. Processing of Clients' personal data to fulfill the purposes stated consists of the following possible actions: collection, storage, clarification, updating, modification, use, transfer, destruction.
• 4.2. Processing of Clients' personal data is done without using any means of automation.
• 4.3. Only the employees of the Hotel who are authorized to work with the personal data of the Clients and who have signed the Agreement on non-disclosure of personal data may have access to the processing of the Clients' personal data.
• 4.4. To follow the current legislation in the field of migration policy of the Hotel transfers personal data of the Clients to the FMS with observance of the norms of personal data protection.
• 4.5 The Hotel does not give the Clients' personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.
• 4.6. There is no international transfer of personal data.

5. Client’s personal data processing policy

• 5.1. The Hotel observes confidentiality of personal data, takes legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, dissemination of personal data, as well as from other unlawful actions.
• 5.2. When processing personal data without using means of automation, the Hotel complies with the requirements established by the Resolution of the Government of the Russian Federation No. 687 dated September 15, 2008 “On Approval of the Regulations on the peculiarities of personal data processing without using means of automation”.
• 5.3. Responsible for the organization of personal data processing in an Individual Entrepreneur P.V. Demchenko is appointed Director Anna Barchevskaya(phone: 8 (8652) 94-17-95.
• 5.4. Technical protection measures used in the hotel include: fire and security alarms, video surveillance and anti-virus protection.
• 5.5. The Hotel has notified the authorized body for the protection of the rights of personal data subjects about the processing of personal data in accordance with the requirements established by the Federal Law “On Personal Data”.
• 5.6. Should any unlawful actions with personal data be detected, the operator is required to eliminate the violation within a period not exceeding three working days from the date of such detection. The operator shall notify the personal data subject of the elimination of the admitted violations.

6. Client’s Rights

• 6.1. The Client has the right to: access to information about themselves, including information confirming the fact of personal data processing, the purpose of such processing, as well as other information specified in Part 7 of Article 14 of the Federal Law 152-ФЗ “On Personal Data”.
• 6.2. The subject of personal data has the right to demand from the operator to clarify their personal data, block or destroy them in case the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights.
• 6.3. If the subject of personal data believes that the operator processes his personal data in violation of the law or otherwise infringes his rights and freedoms, the subject of personal data has the right to appeal the actions or omissions of the operator to the authorized body for the protection of the rights of personal data subjects or in court.

7. Liability for violation of regulations governing the processing of Clients' personal data

• 7.1. The Hotel is responsible for the personal information in its possession and establishes the personal responsibility of its employees for compliance with the existing confidentiality regime.
• 7.2. Each employee who receives for work a document containing the Client's personal data is solely responsible for the safety of the data storage and confidentiality of the information.
• 7.3. The Hotel's employees are responsible for the proper handling of Customer inquiries, applications and complaints, as well as for assisting in the fulfillment of the requirements of competent authorities.
• 7.4. Persons guilty of violating the norms regulating the obtaining, processing and protection of Clients' personal data shall be held accountable for disciplinary, administrative, civil or criminal liability in accordance with federal laws.