Privacy Policy

I. General Provisions
1.1. The policy regarding the processing of personal data (hereinafter referred to as the Policy) is aimed at protecting the rights and freedoms of individuals whose personal data is processed by «KULU» LLC (hereinafter referred to as the Operator).
1.2. The policy was developed in accordance with clause 2, part 1, art. 18.1 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter referred to as Federal Law No. 152 FZ).
1.3. This Policy applies to the activities of all employees and structural divisions of the company involved in the processing of personal data.
1.4. Terms and Definitions. Personal data (PD) - any information relating to a directly or indirectly identified or identifiable individual (subject of personal data). Processing of personal data - any action (operation) or set of actions (operations) performed using automation tools or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, presentation, access), depersonalization, blocking, deletion, destruction of personal data.
Providing personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons. Dissemination of personal data - actions aimed at disclosing personal data to an indefinite number of persons.
Destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material media of personal data are destroyed. Depersonalization of personal data - actions as a result of which it becomes impossible to determine the ownership of personal data to a specific subject of personal data without the use of additional information.
Personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
Cross-border transfer of personal data is the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
I I . Purposes of collecting personal data, volume of personal data processed, categories of personal data subjects, methods and terms of processing
2.1. The operator processes personal data on a legal and fair basis to fulfill the functions, powers and duties assigned by law.
2.2. Conditions for processing personal data collected using the site functionality:
2.1.1. By filling out application forms for tours, as well as logging onto the site, the user consents to the processing of personal data in accordance with this Personal Data Processing Policy.
2.2.2. Consent to the processing of personal data can be withdrawn by sending a written application to the Operator in any available way.
If the subject of personal data withdraws consent to 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 paragraphs 2 - 11 of part 1 of article 6 of Federal Law No. 152 FZ.
2.3. Purposes of processing, list of personal data processed, categories of personal data subjects:
for the purpose of applying for tours, sending an application, receiving a call back, messages, personal data is processed: last name, first name, patronymic, email address, phone number, site users;
for the purpose of analyzing traffic, user activity, optimizing the site, targeting advertising using the Internet services Yandex Metrica, Tilda, personal data is collected: user IP address, JavaScript events, page URL, browser and its version, Flash version, silverlight version, visit, age, gender, interests, geographic location of the user, time on the site, screen height and width, viewing depth, screen color depth, date and time of site visit, page title, interests of visitors, information about user behavior on the site (including number and name of pages viewed), source of entry to the site, presence of Cookies, presence of Java, presence of JavaScript, access, operating system and its version, refusal, page loading parameters, password, clicking on an external link, page view, other technical data (cookies, flash , java, etc.), page referrer, type and model of mobile device, types of browser and operating systems, time zone, width and height of the client part of the browser window, email, browser language of site users.
2.4. Processing methods, list of actions with personal data.
2.4.1. The operator processes personal data using and without automation tools.
2.4.2.Actions for processing personal data include collection, recording, systematization, storage, retrieval, use, transfer (provision, access), blocking, deletion and destruction.
2.4.3. Personal data can be transferred to officials in the event of receipt of motivated requests from government bodies (Ministry of Internal Affairs, Prosecutor's Office, Investigative Committee, FSB).
2..5. Terms of processing and storage of personal data.
2.5.1. Processing and storage time: 1 year.
2.6. Procedure for destruction of personal data.
2.6.1. The processed personal data is subject to destruction or depersonalization upon achievement of the processing goals or in the event of the loss of the need to achieve these goals, unless otherwise provided by federal law.
2.6.2. When the processing goals are achieved and the storage period expires, the paper media and content of personal data are destroyed by shredding.
2.6.3. The destruction of personal data contained in information systems at the end of their processing period is carried out by removing them from electronic media using methods and means of guaranteed removal of residual information.
2.7. Cross-border transfer of personal data is not carried out.
I I I . Measures to organize the processing and ensure the security of personal data
3.1. When processing personal data, the operator takes the necessary legal, organizational and technical measures or ensures their adoption to protect personal data from unauthorized or accidental access to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in regarding personal data.
3.2. Ensuring the security of personal data is achieved, in particular, in the following ways:
- appointment of a person responsible for organizing the processing of personal data, whose rights and obligations are determined by local acts of the company;
- carrying out internal control and/or audit of compliance of the processing of personal data with the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" and the regulatory legal acts adopted in accordance with it, requirements for the protection of personal data, local acts of the company;
- familiarizing the company's employees directly involved in the processing of personal data with the provisions of the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data, local regulations regarding the processing of personal data and/or training of these employees;
- identifying threats to the security of personal data during their processing in personal data information systems;
- application of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems necessary to fulfill the requirements for the protection of personal data;
- assessing the effectiveness of measures taken to ensure the security of personal data before the commissioning of the personal data information system;
- taking into account machine (material) storage media of personal data;
- identifying facts of unauthorized access to personal data and taking appropriate measures;
- restoration of personal data modified or destroyed due to unauthorized access to it;
- establishing rules for access to personal data processed in the personal data information system, as well as ensuring registration and accounting of all actions performed with personal data in the personal data information system;
- control over compliance with requirements in the field of ensuring the security of personal data and the levels of security of personal information systems.
3.3. Measures to ensure the security of personal data during processing carried out without the use of automation tools.
3.3.1. The processing of personal data, carried out without the use of automation tools, is carried out in such a way that for each category of personal data it is possible to determine the storage locations of personal data (tangible media) and establish a list of persons processing personal data or having access to it.
3.3.2 Separate storage of personal data (tangible media) is ensured, the processing of which is carried out for various purposes.
3.3.3. When storing material media, conditions are observed that ensure the safety of personal data and exclude unauthorized access to it. The list of measures necessary to ensure such conditions, the procedure for their adoption, as well as the list of persons responsible for the implementation of these measures are established by the operator.
I V. Rights of the subject of personal data
4.1. The subject of personal data has the right to receive information about the processing of his personal data, including those containing:
- information about the company as an operator processing personal data (name and location);
- availability of personal data in society;
- confirmation of the fact of processing of the company's personal data, indication of the legal grounds and established purposes of processing personal data;
- methods of processing personal data used in society;
- information about persons who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the company (including instructions from the operator) or on the basis of federal law(s), with the exception of employees, access to which was granted in connection with the performance of official (functional) duties;
- a list of processed personal data related to a specific subject of personal data and the source of their receipt;
- terms of processing of personal data, including periods of their storage;
- the procedure for exercising the rights of personal data subjects provided for by the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data";
- information about the ongoing or intended cross-border transfer of personal data, indicating the name of the country (the company does not carry out cross-border data transfer);
- information on how the operator fulfills the obligations established by Article 18.1 of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data";
- other information provided for by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," which may include compliance with the conditions and principles of processing personal data, information on compliance with requirements for ensuring the security of personal data, possible restrictions on subjects' access to their personal data.
4.2. To exercise the rights and legitimate interests, the subject of personal data has the right to contact the society. The request must contain the number of the main document identifying the subject of personal data, his legal representative, information about the date of issue of the specified document and the issuing authority and a handwritten signature. The request can be sent in electronic form and signed with an electronic signature in accordance with the current legislation of the Russian Federation.
Operator contacts for PD subjects regarding personal data processing: Magadan, st. Proletarskaya 84 A, 685030, tel. 606-702, e-mail: info@piyaginatours.com
4.3. The subject of personal data has the right to demand clarification of his personal data, its blocking or destruction if it is incomplete, outdated, inaccurate, illegally obtained or cannot be considered necessary for the declared processing, as well as take measures provided by law to protect his rights.
4.4. The right of the subject of personal data to access his personal data may be limited in accordance with federal laws, including if the subject of personal data's access to his personal data violates the rights and legitimate interests of third parties.
4.5. If the subject of personal data believes that the company is processing his personal data in violation of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data", violating his rights and freedoms, the subject of personal data has the right to appeal the actions or inactions of the company to the authorized body for protection of the rights of personal data subjects or in court.
4.6. The subject of personal data has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damage in court.
V. Responsibility
5.1. Persons guilty of violating the requirements of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" bear responsibility under the legislation of the Russian Federation.
5.2. Moral damage caused to the subject of personal data as a result of violation of his rights, violation of the rules for processing personal data established by this Federal Law, as well as the requirements for the protection of personal data established in accordance with this Federal Law, is subject to compensation in accordance with the legislation of the Russian Federation. Compensation for moral damage is carried out regardless of compensation for property damage and losses incurred by the subject of personal data.
© 2024 KULU SAFARIS
We provide hunts for the Yakut, Kolyma and Okhotsk Snow Sheep (We are the only company that can organize hunts for all three subspecies in one tour)
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ООО "Кулу"
ИНН/КПП 4909076660/490901001
ОГРН 1024900964483
Тел: 8 (413 2) 64-49-30; 60-67-02
Email : kulusafaris@gmail.com