Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by amarastour.am (hereinafter — the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of the right to privacy and personal and family confidentiality, to be its most important goal and a mandatory condition of its activities.
1.2. This Policy of the Operator regarding personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://amarastour.am.
2. Key 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 set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at https://amarastour.am.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without using additional information, the ownership of personal data by a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out personal data processing and determines the purposes of processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://amarastour.am.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access is granted to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data permitted for dissemination in accordance with the procedure provided by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://amarastour.am.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination 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 available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or granting 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, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed, making it impossible to restore their content in a personal data information system and/or physical media containing personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain reliable information and/or documents containing personal data from the personal data subject;
— in the event of withdrawal of consent by the personal data subject or submission of a request to terminate personal data processing, continue processing personal data without consent if there are grounds provided by the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided 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 personal data subject, upon request, with information relating to the processing of their personal data;
— organize personal data processing in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of personal data subjects’ rights with necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions;
— terminate the transfer (dissemination, provision, access), terminate processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided 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 disclosure. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand clarification, blocking, or destruction of their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to personal data processing and submit a request to terminate such processing;
— appeal unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of personal data subjects’ rights or to a court;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator of any clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that subject’s consent shall bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.
5.3. It is not permitted to merge databases containing personal data processed for purposes 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 processed personal data correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not permitted.
5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form allowing identification of the personal data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Upon achievement of processing purposes or loss of necessity to achieve them, personal data are destroyed or depersonalized, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails
Personal data:
— last name, first name, patronymic
— email address
— phone numbers
Legal grounds:
Federal Law No. 149-FZ of July 27, 2006 “On Information, Information Technologies, and Information Protection”
Types of personal data processing:
Transfer of personal data
7. Conditions for Processing Personal Data
7.1. Personal data processing is carried out with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties imposed on the Operator by Russian legislation.
7.3. Processing is necessary for the administration of justice or execution of judicial or other enforceable acts in accordance with Russian legislation on enforcement proceedings.
7.4. Processing is necessary for the performance or conclusion of a contract involving the personal data subject as a party, beneficiary, or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out for personal data made publicly available by the personal data subject or at their request.
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with applicable personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2. The User’s personal data will never be transferred to third parties, except as required by law or with the consent of the personal data subject for fulfillment of obligations under a civil law contract.
8.3. If inaccuracies are identified, the User may update personal data by sending a notification to amarastour.am@gmail.com with the subject “Updating Personal Data.”
8.4. The processing period is determined by the achievement of the purposes for which personal data were collected, unless otherwise provided by contract or law. The User may withdraw consent at any time by emailing amarastour.am@gmail.com with the subject “Withdrawal of Consent to Personal Data Processing.”
8.5. Information collected by third-party services (including payment systems and communication providers) is stored and processed by such parties in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of third parties.
8.6. Restrictions established by the personal data subject on the transfer or processing of personal data permitted for dissemination do not apply in cases of processing in state, public, or other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data.
8.8. Personal data are stored no longer than required by the purposes of processing unless otherwise established by law or contract.
8.9. Grounds for termination of processing include achievement of processing purposes, expiration or withdrawal of consent, a request to terminate processing, or identification of unlawful processing.
9. List of Actions Performed by the Operator with Personal Data
9.1. Collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction.
9.2. Automated processing with or without transfer of information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing cross-border transfer, the Operator must notify the authorized body for the protection of personal data subjects’ rights.
10.2. Prior to submitting such notification, the Operator must obtain relevant information from foreign authorities, individuals, and legal entities to whom personal data will be transferred.
11. Confidentiality of Personal Data
The Operator and other persons with access to personal data must not disclose or disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain clarifications regarding personal data processing by contacting the Operator at amarastour.am@gmail.com.
12.2. Any changes to the 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 publicly available on the Internet at https://amarastour.am/policy.
1. General Provisions
This Personal Data Processing Policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data by amarastour.am (hereinafter — the Operator).
1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the protection of the right to privacy and personal and family confidentiality, to be its most important goal and a mandatory condition of its activities.
1.2. This Policy of the Operator regarding personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://amarastour.am.
2. Key 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 set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at https://amarastour.am.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine, without using additional information, the ownership of personal data by a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out personal data processing and determines the purposes of processing, the composition of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://amarastour.am.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which access is granted to an unlimited number of persons by the personal data subject by giving consent to the processing of personal data permitted for dissemination in accordance with the procedure provided by the Personal Data Law (hereinafter — personal data permitted for dissemination).
2.10. User — any visitor to the website https://amarastour.am.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination 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 available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or granting 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, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed, making it impossible to restore their content in a personal data information system and/or physical media containing personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain reliable information and/or documents containing personal data from the personal data subject;
— in the event of withdrawal of consent by the personal data subject or submission of a request to terminate personal data processing, continue processing personal data without consent if there are grounds provided by the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided 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 personal data subject, upon request, with information relating to the processing of their personal data;
— organize personal data processing in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of personal data subjects’ rights with necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions;
— terminate the transfer (dissemination, provision, access), terminate processing, and destroy personal data in the manner and cases provided by the Personal Data Law;
— fulfill other obligations stipulated by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided by federal laws. The information is provided 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 disclosure. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand clarification, blocking, or destruction of their personal data if such data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— require prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to personal data processing and submit a request to terminate such processing;
— appeal unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of personal data subjects’ rights or to a court;
— exercise other rights provided by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— inform the Operator of any clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that subject’s consent shall bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collection is not permitted.
5.3. It is not permitted to merge databases containing personal data processed for purposes 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 processed personal data correspond to the stated purposes of processing. Excessive personal data processing in relation to the stated purposes is not permitted.
5.6. Accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form allowing identification of the personal data subject for no longer than required by the purposes of processing, unless the retention period is established by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor. Upon achievement of processing purposes or loss of necessity to achieve them, personal data are destroyed or depersonalized, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User by sending emails
Personal data:
— last name, first name, patronymic
— email address
— phone numbers
Legal grounds:
Federal Law No. 149-FZ of July 27, 2006 “On Information, Information Technologies, and Information Protection”
Types of personal data processing:
Transfer of personal data
7. Conditions for Processing Personal Data
7.1. Personal data processing is carried out with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes provided by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties imposed on the Operator by Russian legislation.
7.3. Processing is necessary for the administration of justice or execution of judicial or other enforceable acts in accordance with Russian legislation on enforcement proceedings.
7.4. Processing is necessary for the performance or conclusion of a contract involving the personal data subject as a party, beneficiary, or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing is carried out for personal data made publicly available by the personal data subject or at their request.
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully comply with applicable personal data protection legislation.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2. The User’s personal data will never be transferred to third parties, except as required by law or with the consent of the personal data subject for fulfillment of obligations under a civil law contract.
8.3. If inaccuracies are identified, the User may update personal data by sending a notification to amarastour.am@gmail.com with the subject “Updating Personal Data.”
8.4. The processing period is determined by the achievement of the purposes for which personal data were collected, unless otherwise provided by contract or law. The User may withdraw consent at any time by emailing amarastour.am@gmail.com with the subject “Withdrawal of Consent to Personal Data Processing.”
8.5. Information collected by third-party services (including payment systems and communication providers) is stored and processed by such parties in accordance with their User Agreements and Privacy Policies. The Operator is not responsible for the actions of third parties.
8.6. Restrictions established by the personal data subject on the transfer or processing of personal data permitted for dissemination do not apply in cases of processing in state, public, or other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data.
8.8. Personal data are stored no longer than required by the purposes of processing unless otherwise established by law or contract.
8.9. Grounds for termination of processing include achievement of processing purposes, expiration or withdrawal of consent, a request to terminate processing, or identification of unlawful processing.
9. List of Actions Performed by the Operator with Personal Data
9.1. Collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction.
9.2. Automated processing with or without transfer of information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing cross-border transfer, the Operator must notify the authorized body for the protection of personal data subjects’ rights.
10.2. Prior to submitting such notification, the Operator must obtain relevant information from foreign authorities, individuals, and legal entities to whom personal data will be transferred.
11. Confidentiality of Personal Data
The Operator and other persons with access to personal data must not disclose or disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain clarifications regarding personal data processing by contacting the Operator at amarastour.am@gmail.com.
12.2. Any changes to the 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 publicly available on the Internet at https://amarastour.am/policy.
