CONFIDENTIALITY POLICY

Moscow Region, Mytishchi

March 11, 2017

 

This confidentiality policy (hereinafter referred to as the “Confidentiality Policy” or the “Policy”) is applied in respect to all information the MG-Group Limited Liability Company (hereinafter referred to as the “Personal Data Operator” or the “Operator”) can obtain about an individual (hereinafter referred to as the “User”) when using the “Hotel Remote Control” mobile application (hereinafter referred to as the “Mobile Application”).

For the purpose hereof, the domain (domain name) is interpreted as a unique address on the Internet used by the Operator legally to provide Users with access to the Mobile Application and program modules (services) respectively.

When downloading, installing, registering, obtaining access, and otherwise using the Mobile Application, the User, as well as individuals in whose interests the User acts unconditionally accept all terms and conditions hereof and give their consent to processing their personal data. In case of disagreement with the terms and conditions hereof, the User must not use the Mobile Application.

The Operator has the right to amend this Policy without informing the User in writing. The User individually follows the Policy subject to its amendments. In case of using the Mobile Application, the User confirms their consent with the new version of the Policy.

  1. Goals of Collecting and Processing the User’s Personal Data

The Operator collects, processes and stores only the User’s personal data required for providing services of the Mobile Application, functioning and supporting the current capacities of the Mobile Application.

The Operator has the right to use the User’s personal data for the purpose of

  • Identifying the User,
  • Providing the User with personalized services,
  • Providing the User with the support services,
  • Sending notices, requests and information related to using services of the Mobile Application, as well as processing the User’s requests,
  • Improving the quality of the Mobile Application, convenience of using it, and developing new services,
  • Conducting statistical, marketing and other researches, based on the anonymized data,
  • Performing advertising activity with the consent of the User, and
  • Providing the User with the access to the websites and services of the Operator’s partners to obtain products, updates and services.

The User’s data can be also processed by the Operator’s affiliates and partners.

  1. User’s Personal Data

“The User’s Personal Data” is interpreted within this Policy as

— any personal data (information) the User provides about himself or herself individually or about third parties on their behalf when registering, creating the account, and using services of the Mobile Application, including but not limited to the following data: a surname, a name, a patronymic name, a birthdate, a gender, citizenship, passport series and number, residence or registration address, home or mobile phone, email, details of the bank card or another electronic payment means, etc. Thereby, the Operator shall have the right but must not verify the veracity of the personal data provided by the User on his or her behalf or on third parties’ behalf, and control their legal capability. The User shall bear responsibility for invalid data individually. The data that is obligatory for using services of the Mobile Application is specially marked. Other information shall be provided by the User at his or her discretion. The Operator can ask additional data to be provided by the User voluntarily and optionally.

  • Data that is automatically transferred to the Mobile Application when using it with the aid of the software installed on the User’s device including IP address, data about the mobile network and the User’s phone number, cookies information, information about the operational system/browser of the User (or any other software that provides access to the Mobile Application), information about the User’s location including GPS data sent by the mobile device, time of access, etc., and
  • Other data about the User and third parties whose collecting and providing is defined in the documents regulating the procedure of providing various services through the Mobile Application.

When using the User’s personal data, the Operator shall be governed by this Confidential Policy and the current legislation of the Russian Federation.

  1. Processing, Storage and Transfer of Personal Data

The User’s personal data shall be processed without limiting the term and shall include any action (operation) or a combination of actions (operations) made by the Operator to provide, manage and develop the Mobile Application by using or without using means to automate personal data, including collecting, recording, systematization, accumulating, storage, clarifying (updating, changing), modification, extracting, using, transferring (distribution, provision, access), including trans-boundary transfer, anonymizing, blocking, deleting, and destruction of personal data.

The Operator shall store the User’s personal data during the term of providing the User with the access to (using) the Mobile Application/services of the Mobile Application unless another term is provided by the current legislation of the Russian Federation.

When deleting and/or modifying such User’s data, the Operator shall reserve the right to store such data that is required for complying with the current law of the Russian Legislation, providing safety and efficiency of the Mobile Application.

The Operator shall be obliged to take all possible measures to ensure safety and protect the User’s data from unsanctioned attempts to access, change, block, copy, disclose or destruct, as well as from other illegal actions related to them by third parties. In particular, the Operator shall improve the ways of collecting, storing, and processing the User’s personal data.

The User shall be obliged to keep the account data (login and password) in secret from third parties and immediately inform the Operator in case of suspecting the unsanctioned use of his or her account.

The User shall have the right to revoke the consent to process his or her personal data based on the written request handed or sent as a registered letter with the delivery notice to the Operator’s at its location.

In case of revoking the consent to process personal data, all information obtained from the User as well as login and password shall be deleted within thirty days as of the above revocation. After that the User shall not have the access to the Mobile Application.

The confidentiality mode is effective in relation to the User’s personal data.

The User shall give his or her consent to the Operator’s transfer of the User’s personal data to the Operator’s affiliates and partners for the purposes provided by Chapter 1 hereof, as well as for ensuring the functioning of the Mobile Application/services of the Mobile Application and meeting the User’s need in services.

The Operator shall have the right to transfer the User’s personal data to third parties in the following cases:

— The User expressed his or her consent for such actions,

— The transfer is required within using the Mobile Application by the User or for providing services,

— The transfer is provided for by the legislation of the Russian Federation within the procedure determined by the legislation,

— Transfer within selling or another transfer of business (entire or partial); thereby, all obligations on complying hereof as applied to the obtained Users’ personal data shall be transferred to the transferee, and

— For providing the opportunity to protect rights and legal interests of the Operator or third parties in case the User violates the terms and conditions hereof.

In the cases provided by the Federal Act “On Personal Data”, special categories of the User’s personal data are processed only subject to the User’s written consent. The User’s written consent for processing his or her personal data may include a surname, a name, a patronymic name, the User’s address, number of the main document identifying the personality, data about the date of the main document and the body that issued it, the Operator’s name and address, the goal of processing personal data, a list of personal data whose processing is approved by the User, general description of the ways of processing personal data used by the Operator, the term of the consent and its revocation procedure.

If the User is incapable, the consent for processing his or her personal data shall be given in writing by the User’s legal representative.

In case of the User’s death, the consent for processing his or her personal data shall be given in writing by the User’s successors if the User has not given such consent when alive.

The Operator shall not control and shall not bear responsibility for websites of third parties the User can access by using the links that are available in the Mobile Application.

 

  1. Final Provisions

The law of the Russian Federation is applicable in relation hereto and relationships between Users and the Operator that arise when using it (the Mobile Application “Hotel Remote Control”).

All issues and offers related to the terms and conditions of the Confidentiality Policy and/or processing the User’s personal data in connection with using the Mobile Application shall be sent to the Operator at the following address: 26, Kolpakov St., Apе. 2, Prem. XII Mytishchi, Moscow Region, 141008, the Russian Federation, or emailed to the Mobile Application Support to hello@hotelrc.ru.

If the User contacts the Operator and/or the Mobile Application Support with a written request, the Operator shall have the right to ask additional data required to consider the relevant request. If no additional data are provided, the Operator and/or the Mobile Application Support may not consider the User’s request.

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