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Personal Data Processing Policy

Personal Data Processing Policy

Privacy Policy Approved by the Manager of Welton Club Hotel & Apartments

Kirillova Anastasia Ruslanovna

July 10, 2021


This Privacy Policy (further- the "Policy") governs the relationship between the owner of the website (further - the "Company" or Individual Entrepreneur Saakyan Henrikh Armarovich, the hotel "Welton Club Hotel & Apartments"), on the one side, and any individual,
using the website, on the other side (further referred to as the "User"), when collectively referred to as the "Parties", and separately - the "Side".

This Policy is an offer addressed to any person and can be accepted by a person by joining the Policy as a whole.


1.1. This privacy policy of personal data (further referred to as the Privacy Policy) works with the following concepts:

"Administration of the site (further referred to as the Site Administration)" - specialists representing the interests of the Company, whose duties include managing the website, organizing and (or) processing the personal data received on it. To fulfill these responsibilities, they must clearly understand why the information is processed, what information must be processed, what actions (operations) must be performed with the information received.

"Personal data" - information that is directly or indirectly related to a specific or identifiable individual (also called the subject of personal data).

"Processing of personal data" - any operation (action) or a combination of those that the Administration website performs with personal data. They can be collected, recorded, systematized, accumulated, stored, refined (updated or modified if necessary), extracted, used, transmitted (distributed, provided, made available to them), depersonalized, blocked, deleted and even destroyed. These operations (actions) can be performed both automatically and manually.

"Confidentiality of personal data" is a mandatory requirement for the Operator or any other official working with the User's data to keep the information received in secret, not letting outsiders know about it, if the User who provided the personal data has not expressed his consent, and there is also no legal basis for disclosure/

"Site user" (further referred to as the User) "- a person who has visited the site https: //, and also uses its programs and products.

"Cookies" is a short piece of data sent by a web browser or web client to a web server in an HTTP request, whenever the User tries to open a page on the site. The fragment is stored on the User's computer.

"IP-address" is a unique network address of a node in a computer network built using the protocol TCP / IP.

2.                                                                                                                           GENERAL PROVISIONS

2.1  Viewing the pages of the website, as well as the use of its programs and products, imply automatic consent to the Privacy Policy adopted there, which implies the provision of personal data by the User for processing.

2.2 If the User does not agree with this Privacy Policy, the User must leave the site

2.3 The available Privacy Policy applies only to the website If, following the links posted on the website of the latter, the User enters the resources of third parties, the Administration of the site is not responsible for its actions.

2.4 Checking the accuracy of personal data that the User who has accepted the Privacy Policy decided to report is not the responsibility of the Site Administration.

3.                                                                                                                              THE PRIVACY POLICY

3.1  According to this Privacy Policy, the Site Administration is obliged not to disclose personal data provided by Users who register on the site or place an order for the purchase of goods, the provision of services, and also to provide this data with absolute confidentiality.

3.2  In the process of using the website, the User may transfer the following information to the Company:

Personal data provided by the User independently when filling out the room reservation form, including but not limited to: last name, first name, patronymic, gender, date of birth, contact numbers, e-mail address. The information required for provision is marked with special markings, the rest of the information is provided at the discretion of the Users;

Technical information that is automatically transmitted to the Company in the process of using the site with the help of the software installed on the User's device, including: IP-address, information from cookies, information about the User's browser or other program, from with the help of which the access to the site is carried out, the time of access, the address of the requested page, about the device of the User, with the help of which the access to the site is carried out.

3.3 The user can change the settings for accepting cookies in the settings of his browser or disable them completely, however, in this case, some functions of the site may not work correctly.

3.4 The site collects statistics about the IP addresses of all visitors. This information is needed to identify and solve technical problems and control how legal the financial payments will be.

3.5 Any other personal information not specified above (about when and what purchases and orders were made, which browser was used, which operating system was installed, etc.) is securely stored and not distributed. An exception to the existing Privacy Policy provides for cases, described in p. 5.5 and 5.4.

3.6  If the user chooses the online payment system for the services of the Apart-hotel, the payment is made through a secure channel of the Internet acquiring payment system. In this case, information about

the User's bank card is not stored on the server of the site, and as a result is not an object of personal data.


4.1 The Company collects and processes only the information that is necessary to provide the User with services in accordance with the functionality of the Software.

4.2   The Company may process information provided by the User, including Personal Data, for the following purposes:

·        User identification and provision of services in accordance with the functionality of the Software, including, but not limited to, online booking of a hotel selected by the User, as well as ordering other services.
·        Communication with the User, including sending notifications, requests and information regarding the use of the Company's services, as well as processing requests and requests from the User;
·        Conducting statistical, analytical and other studies based on anonymized data;
·        Processing and receiving payments, returning funds to the User.

5.                                                                WAYS AND TERMS OF PROCESSING PERSONAL INFORMATION

5.1  The processing of User information, including Personal data, is carried out with the consent of the User given in the process of using the site. The User decides to provide information, including Personal Data, and agrees to their Processing freely, of his own free will and in his interest. Consent to the Processing of information is given by the User at the time of the Acceptance of this Policy.

5.2 Information processing is carried out by the Company using automation tools in accordance with this Policy and the internal acts of the Company.

5.3 Information processing is carried out in strict accordance with the law.

5.4  The Company undertakes to maintain confidentiality and not to distribute the User's information without the consent of the User. The company undertakes not to disclose to third parties, distribute, sell, alienate, or otherwise dispose of the information received, except for the purposes and methods provided for in this
Policy as well as legislation.

5.5 The Company has the right to transfer the User's Personal Data to third parties solely for the purpose of fulfilling their contract for the provision of hotel and / or other services related to hotel services, to which the User is or will be a party. Consent to the transfer of information, including Personal Data, to these third parties is given by the User at the time of Acceptance of this Policy.

5.6 The Company ensures that the necessary and sufficient legal, organizational and technical measures are taken to protect the User's information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties with it.

5.7 The user guarantees that any information provided by him to the Company in the process of using the site is received by him on a legal basis. The company is not responsible for the actions of the User with information, including, but not limited to, cases when the information provided is a commercial or other secret protected by law.

5.8 The term for processing the User's personal data is not limited by anything. The processing procedure can be carried out in any way provided by law. In particular, with the help of personal data information systems, which can be maintained automatically or without automation.


6.1 It is the responsibility of the User to provide information about himself that meets the requirements of the site.

6.2 The responsibilities of the Site Administration include:

6.3 Application of the information received solely for the purposes specified in clause p.4 of the existing Privacy Policy.

6.4 Ensuring the confidentiality of information received from the User. They should not be disclosed unless the User gives written permission to do so. Also, the Administration does not have the right to sell, exchange, publish or disclose in other ways the personal data transferred by the User, excluding p. 5.5 of the existing Privacy Policy.

6.5  Taking precautions so that the User's personal data remains strictly confidential, just as this kind of information remains confidential in modern business.

6.6 Blocking of personal user data from the moment from which the User or his legal representative makes a corresponding request. The right to make a request for blocking is also granted to the body authorized to protect the rights of the User who provided the Site Administration with his data, for the period of verification, in case of unreliability of the reported personal data or illegal actions.

7.                                                                                                            RESPONSIBILITY OF THE PARTIES

7.1 In case of non-fulfillment by the Site Administration of its own obligations and, as a result, the User's losses incurred due to the unlawful use of the information provided by him, the responsibility rests with her. This, in particular, is approved by Russian legislation. The currently existing Privacy Policy makes an exception for the cases reflected in p. 5.5.

7.2 But there are a number of cases when the Site Administration is not responsible if user data is lost or disclosed. This happens when they:

·        Became public domain before they were lost or disclosed.

·        Were provided by third parties before they were received by the Site Administration.

·        Disclosed with the consent of the User.


8.1 If the User is dissatisfied with the actions of the Site Administration and intends to defend his rights in court before filing a claim, he must make a claim (in writing to offer to settle the conflict voluntarily).

8.2  The Administration that received the claim is obliged, within 30 calendar days from the date of its receipt, to notify the User in writing about its consideration and the measures taken.

8.3  If both parties could not agree, the dispute is referred to the judicial authority, where it must be considered in accordance with the current Russian legislation.

8.4 The regulation of the relationship between the User and the Site Administration in the Privacy Policy is carried out in accordance with the current Russian legislation.


9.1 The site administration has the right to change this Privacy Policy without asking the User for consent.

9.2 The entry into force of the new Privacy Policy begins after information about it is posted on the website https: //, unless the changed Policy implies a different placement option.

9.3 All suggestions, wishes, requirements or questions about this Privacy Policy should be communicated by sending an email to:

9.4    You can read about the existing Privacy Policy by going to the main page of the site