Privacy Policy

1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by LLC "Alex Residence Hotels" (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family secrets, to be its most important goal and condition for carrying out its activities.

1.2. This Operator’s policy regarding personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://alexresidence.ru.

2. Basic 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 cessation of processing of personal data (except when processing is necessary to clarify personal data).

2.3. Website — a set of graphic and informational materials, as well as computer programs and databases ensuring their availability on the Internet at https://alexresidence.ru.

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 resulting in the impossibility of determining, without additional information, the принадлежность (affiliation) of personal data to a specific User or other subject of personal data.

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, destruction of personal data.

2.7. Operator — a state body, municipal authority, legal entity or individual that independently or jointly organizes and/or carries out personal data processing, and determines the purposes, composition of personal data, and actions performed on personal data.

2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://alexresidence.ru.

2.9. Personal data permitted for distribution — personal data to which access is granted to an unlimited number of persons by the data subject by giving consent for processing in accordance with the Personal Data Law.

2.10. User — any visitor of the website https://alexresidence.ru.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group of persons.

2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons or making them accessible to the public.

2.13. Cross-border transfer of personal data — transfer of personal data to a foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data — actions resulting in the irreversible destruction of personal data.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

• receive reliable information and/or documents containing personal data from the data subject;

• continue processing personal data without consent in cases предусмотренных (provided for) by law;

• independently determine necessary and sufficient measures to comply with legal requirements.

3.2. The Operator is obliged to:

• provide information on personal data processing upon request;

• organize processing in accordance with Russian legislation;

• respond to requests of data subjects;

• provide required information to authorized authorities within 10 days;

• publish this Policy or ensure unrestricted access to it;

• take legal, organizational, and technical measures to protect personal data;

• stop processing and destroy data when required by law;

• fulfill other obligations established by law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Data subjects have the right to:

• receive information about processing of their personal data;

• demand clarification, blocking, or destruction of inaccurate or unlawful data;

• require prior consent for marketing purposes;

• withdraw consent to data processing;

• appeal against unlawful actions of the Operator;

• exercise other rights provided by Russian law.

4.2. Data subjects are obliged to:

• provide accurate data;

• notify the Operator of changes to their personal data.

4.3. Persons providing false data bear responsibility under Russian law.

5. Principles of Personal Data Processing

• lawful and fair processing;

• limitation to specific, legitimate purposes;

• no incompatible data processing;

• only relevant data is processed;

• proportionality of data volume;

• accuracy and relevance ensured;

• storage limited to necessary duration.

6. Purposes of personal data processing

Purpose of processing	providing the User with access to services, information, and/or materials on the website
Personal data	last name, first name, patronymic email address phone numbers
Legal grounds	agreements concluded between the operator and the subject of personal data
Types of personal data processing	collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data Sending information letters to an email address

7. Conditions of Personal Data Processing

Processing is carried out:

• with consent;

• to comply with legal obligations;

• for administration of justice;

• for contract execution;

• for legitimate interests;

• for publicly available data;

• when required by law.

8. Procedure for Collection, Storage, Transfer, and Other Processing

• security ensured through legal, organizational, and technical measures;

• protection from unauthorized access;

• no transfer to third parties unless required by law or consent is given;

• users may update their data via email: alexresidence@yandex.ru;

• users may withdraw consent at any time;

• third-party services process data under their own policies;

• confidentiality is maintained;

• data stored only as long as necessary;

• processing ends upon purpose completion or consent withdrawal.

9. Actions Performed by the Operator

• collection, storage, use, transfer, depersonalization, deletion, destruction;

• automated processing with or without data transmission.

10. Cross-Border Transfer

• Operator must notify authorities before transfer;

• must obtain necessary guarantees from foreign recipients.

11. Confidentiality

Personal data must not be disclosed without consent unless required by law.

12. Final Provisions

• Users may contact the Operator at alexresidence@yandex.ru;

• Policy changes will be reflected in this document;

• Policy is valid indefinitely until replaced;

Current version available at: https://alexresidence.ru/policy/.