Privacy Policy and Personal Data Processing Policy

This Personal Data Processing Policy (hereinafter referred to as the "Policy") has been developed in accordance with the Constitution of the Russian Federation, the Civil Code of the Russian Federation, Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies and Information Protection," Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," and other regulatory legal acts of the Russian Federation adopted pursuant thereto. This Policy is issued and applied by FRESH TOURISM LLC (hereinafter referred to as the "Operator") in compliance with Clause 2, Part 1, Article 18.1 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," with respect to all information that the Operator may obtain about a user during their use of the Operator's websites bearing the domain name freshtourism.ru, including all sections and subdomains thereof (hereinafter referred to as the "Website"). This Policy governs any type of processing of personal data and personally identifiable information (any information that allows an individual to be identified, as well as any other information related thereto) relating to individuals who are consumers of the Operator's products or services. The Policy applies to the processing of personal data collected by any means, whether active or passive, online or offline, from individuals located anywhere in the world.

Any matters relating to the processing of personal data not covered by this Policy shall be resolved in accordance with the applicable personal data legislation of the Russian Federation.

1. Personal Information of Users Collected and Processed by the Website

1.1. "User's personal data" shall mean:

1.1.1. Personal information that the user voluntarily provides to FRESH TOURISM LLC when submitting a request, making a purchase, registering (creating an account), or otherwise using the Website, including: surname, first name; mobile phone number; email address.

1.1.2. Data that is automatically transmitted to the Website during use via the software installed on the user's device, including IP address, cookie data, browser information (or other program used to access the website), access time, requested page address, and other visitor data from web analytics services (such as the address of the page containing an advertising unit, referrer – the address of the previous page, etc.), geolocation data, and other data that is collected and processed automatically on the Website.

This data is used to gather information about visitors' activity on the Website in order to improve its content, enhance its functionality, and consequently create high-quality content and services for visitors.

The data subject may at any time adjust their browser settings to block all cookies or to receive notifications when cookies are being sent. However, the data subject should understand that in such cases, some features and services of the Website may not function properly.

1.1.3. In addition to the information specified in Clauses 1.1.1 and 1.1.2 of this Policy, the Operator also records data regarding purchases made by the data subject on the Website.

1.2. This Policy applies solely to the Website, and the Operator (Website administrator) does not control and is not responsible for third-party websites that the user may access via links available on the Website. Such third-party resources may collect or request other personal information from the user and may perform other actions unrelated to the Operator.

1.3. The Website generally does not verify the accuracy of personal information provided by users and does not exercise control over their legal capacity. The Operator assumes that the user provides accurate and sufficient information in response to the prompts provided on the Website's forms and keeps such information up to date.

2. Purposes of Collecting and Processing Users' Personal Information

2.1. The Website collects and stores only that personal data which is necessary for providing services, selling goods, and/or offering other value to Website visitors.

2.2. The Operator is entitled to use the user's personal information for the following purposes:

2.2.1. Identifying the party under agreements and contracts with the Operator.

2.2.2. Providing the user with personalized services, goods, and other value offerings.

2.2.3. Communicating with the user, including sending notifications, requests, and information related to the use of the Website, the provision of services, as well as processing user inquiries and requests.

2.2.4. Improving the quality of the Website, enhancing its user-friendliness, and developing new products and services.

2.2.5. Targeting informational materials.

2.2.6. Conducting statistical and other research based on the data provided.

2.2.7. Concluding, performing, and terminating civil law contracts with individuals, legal entities, individual entrepreneurs, and other persons in cases provided for by the applicable legislation of the Russian Federation.

2.2.8. Detecting, preventing, mitigating, and investigating fraudulent or other unlawful actions against the Operator.

3. Conditions for Processing Users' Personal Information and Transferring It to Third Parties

3.1. If the user acts on behalf of third parties, the user guarantees to the Operator that they have obtained the consent of such third parties whose personal data they transfer to the Operator.

3.2. Users' personal information is treated as confidential, except in cases where the user voluntarily discloses information about themselves for public access by an unlimited number of persons.

3.3. The Website is entitled to transfer the user's personal information to third parties in the following cases:

3.3.1. The user has expressed their consent to such actions by providing personal data;

3.3.2. The transfer is necessary for the user's use of the Website or for providing goods and/or services to the user;

3.3.3. The transfer is required by Russian legislation in accordance with established procedures;

3.3.4. For the purpose of ensuring the protection of the rights and legitimate interests of the Operator or third parties in cases where the user violates the Terms of Use.

The Operator does not disclose personal data to third parties or distribute such data without the consent of the data subject, except in cases expressly provided for by the applicable legislation of the Russian Federation and this Policy. In particular, the Operator transfers the user's personal data to third parties for the purpose of providing services to the user, while complying with the provisions of this Policy and taking measures to ensure its security.

3.4. The processing of personal data is organized by the Operator based on the following principles:

3.4.1. Lawfulness of the purposes and methods of processing personal data, good faith, and fairness in the Operator's activities;

3.4.2. Accuracy of personal data, its sufficiency for the purposes of processing, and inadmissibility of collecting personal data that is excessive in relation to the purposes stated when collecting personal data;

3.4.3. Processing only personal data that meets the purposes of its processing;

3.4.4. Correspondence of the content and scope of processed personal data to the stated purposes of processing. Processed personal data must not be excessive in relation to the stated purposes of its processing;

3.4.5. Inadmissibility of combining databases containing personal data processed for purposes that are incompatible with each other;

3.4.6. Ensuring the accuracy of personal data, its sufficiency, and, where necessary, its relevance in relation to the purposes of processing personal data. The Operator takes necessary measures or ensures that such measures are taken to delete or clarify incomplete or inaccurate data;

3.4.7. Storing personal data in a form that allows the identification of the data subject for no longer than is required by the purposes of processing personal data.

3.5. Personal data is processed by the Operator for the period necessary to achieve the purposes for which it was collected, by any lawful means, including in personal data information systems using automation tools or without such tools (mixed processing) via the Internet. In any event, the user's personal data is stored and processed for no longer than 10 (ten) years from the date of the user's consent to its processing.

3.6. All personal data is provided (collected) directly from the user as the data subject.

The data subject independently decides whether to provide or not to provide their personal data and gives consent to its processing by the Operator freely, of their own will, and in their own interest.

3.7. The consent specified in Clause 3.6 of this Policy also means the user's consent to receive email and SMS newsletters within the framework of a paid service contract concluded with the Operator or for receiving advertising and marketing materials.

3.8. Consent to the processing of personal data is given by the user when filling out special subscription forms on the Operator's website, when submitting a request for a free service from the Operator (such as registering for a webinar, etc.), concluding the relevant service agreement (public offer), or directly when paying for services under the agreement (accepting the public offer) by placing a checkmark confirming consent to the processing of personal data in a special checkbox. This action has the legal force of written consent.

3.9. Consent to the transfer of personal data to a third party.
The user gives consent to provide FRESH TOURISM LLC with personal data (surname, first name of the user) for the purpose of enabling the user to use the educational platform when the Operator provides services. The user gives such consent when registering on the Operator's platform by placing a checkmark in the corresponding field confirming consent to the processing of personal data in a special checkbox.

4. Modification of Personal Information by the User

4.1. The user may at any time modify (update, supplement) the personal information they have provided, or any part thereof, as well as its privacy settings, by sending a request to the Operator-Website owner via email at: support@freshtourism.ru.

4.2. The user may at any time withdraw their consent to the processing of personal data by submitting a request to the administration via email at: support@freshtourism.ru.

5. Measures Applied to Protect Users' Personal Information

5.1. When processing personal data, the Operator applies legal, organizational, and technical measures to ensure the security of personal data in accordance with Article 19 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data."

Security of personal data is ensured, in particular, by:

5.1.1. Assessing the effectiveness of measures to ensure the security of personal data before such measures are implemented;

5.1.2. Detecting instances of unauthorized access to personal data and taking measures to eliminate them and prevent recurrence;

5.1.3. Restoring personal data that has been modified or destroyed as a result of unauthorized access;

5.1.4. Establishing access rules for personal data processed in the personal data information system, as well as ensuring the registration and recording of all actions performed with personal data in the personal data information system;

5.1.5. Verifying that contracts entered into by the Operator with third parties contain provisions on ensuring the confidentiality of personal data and incorporating such provisions into contracts where necessary;

5.1.6. Monitoring the measures taken to ensure the security of personal data and the security level of personal data information systems.

5.2. Third parties who gain access to personal data on behalf of the Operator undertake to take the necessary organizational and technical measures to ensure the confidentiality of such information on their personal device from which they process personal data.

5.3. Interaction with federal executive authorities on matters relating to the processing and protection of personal data of data subjects whose personal data is processed by the Operator is carried out in accordance with the legislation of the Russian Federation.

5.4. The Operator is obliged to immediately cease, upon the request of the data subject, the processing of their personal data as specified in Part 1 of Article 15 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data."

6. User Responsibility

6.1. Data subjects are obliged to provide the Operator only with accurate personal data and to promptly notify of any changes thereto. At the same time, the Operator does not verify the accuracy of personal data and does not exercise control over the legal capacity of data subjects, and assumes that the data subject provides accurate and sufficient personal information in response to the prompts provided in the registration (subscription, payment) form and keeps such information up to date.
The risk of providing inaccurate personal data lies with the data subject.

6.2. The Operator does not intentionally process personal data of minors. The Operator recommends that the Website be used by persons aged 18 and over. Responsibility for the actions of minors, including their purchase of services on the Website, lies with the legal representatives of the minors. If the Operator becomes aware that it has received personal information about a minor without the consent of their legal representatives, such information will be deleted as soon as reasonably possible.

6.3. The Operator is not responsible for the processing of personal data of third parties that the recipient of the Operator's services has provided as their own. The risk of liability in this case rests with the recipient of the Operator's services who provided inaccurate data.

6.4. If the data subject disagrees with the terms of this Policy, in whole or in part, their use of the Website and its services must be immediately discontinued.

7. Storage of Personal Data

7.1. Personal data is stored in electronic form in the relevant personal data information systems, hosted in databases located on the territory of the Russian Federation.

7.2. Personal data is stored in a form that allows the identification of the data subject for periods that ensure compliance with and achievement of the purposes of processing personal data set out in this Policy.

7.3. Personal data is stored with restricted access, including through the creation of appropriate access levels.

7.4. Personal data contained in different electronic databases and processed for different purposes is stored separately.

8. Termination of Processing and Destruction of Personal Data

8.1. If inaccurate personal data is identified upon the request of the data subject, the Operator is obliged to block the personal data relating to that data subject from the moment of such request for the period of verification, provided that such blocking does not violate the rights and legitimate interests of the data subject or third parties.

8.2. If the inaccuracy of personal data is confirmed, the Operator is obliged, based on the information provided by the data subject, to update the personal data within 7 (seven) business days from the date of submission of such information and to unblock the personal data.

8.3. If unlawful processing of personal data by the Operator is identified, the Operator must cease such unlawful processing within no more than 3 (three) business days from the date of such identification.

If it is impossible to ensure the lawful processing of personal data, the Operator is obliged to destroy such personal data within no more than 10 (ten) business days from the date of identification of the unlawful processing. The Operator must notify the data subject of the rectification of violations or the destruction of personal data.

8.4. If the data subject withdraws their consent to the processing of personal data, the Operator is obliged to cease processing and, if the retention of personal data is no longer required for the purposes of processing, to destroy the personal data within no more than thirty business days from the date of receipt of such withdrawal.

8.5. The Operator sends notifications regarding the results of consideration of data subject requests specified in this section via the support service at support@freshtourism.ru by sending messages to the data subject's email address specified in the request.

9. Dispute Resolution

9.1. Prior to filing a lawsuit regarding disputes arising from the relationship between the data subject and the Operator, the submission of a claim (a written proposal for voluntary dispute settlement) is mandatory.

9.2. The recipient of the claim shall, within 30 (thirty) calendar days from the date of receipt of the claim, notify the claimant in writing of the results of consideration of the claim.

9.3. If an agreement is not reached, the dispute shall be referred for consideration to the judicial authority at the place of registration of the Operator in accordance with the applicable legislation of the Russian Federation.

9.4. This Personal Data Processing Policy and the relationship between the data subject and the Operator are governed by the applicable legislation of the Russian Federation.

10. Additional Terms

10.1. The Operator is entitled to make changes to this Personal Data Processing Policy without the consent of data subjects.

10.2. The new version of this Personal Data Processing Policy takes effect from the moment it is posted on the Website, unless otherwise provided for in the new version of the Policy.

10.3. Suggestions and comments for amendments to this Personal Data Processing Policy should be sent to: support@freshtourism.ru.

10.4. The invalidity of individual provisions of this Policy, if so recognized by a court decision or other authorized state body, shall not invalidate the Policy as a whole.

10.5. When processing personal data, the Operator does not specifically verify the existence of any special personal data processing regime established by the legislation of countries under whose jurisdiction individual recipients of the Operator's services or persons who have provided their data through the subscription form on the Website may fall. If the data subject is a resident of a state with a special personal data protection regime, such as the European Economic Area (EEA), and accesses the Website from European countries, the Operator takes all reasonable measures to ensure compliance with the personal data protection requirements established by the relevant state or group of states (GDPR). For this purpose, the data subject is obliged to notify the Operator of the existence of a special regime for the protection of their personal data by contacting the support service at support@freshtourism.ru.

11. Operator Details

FRESH TOURISM LLC
Primary State Registration Number (OGRN): 1153850048659
Taxpayer Identification Number (INN): 3808192517
Registered in the Register of Tour Operators
Registration No.: В031-00161-00/03900503

Legal Address: 664003, Irkutsk Region, Irkutsk City Municipality, Irkutsk, Chekhova St., Bldg. 2, Office 118