Policy on Personal Data Processing
1. General Provisions
This personal data processing policy is drafted in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (hereinafter, the “Personal Data Law”) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by Property & Bike Phuket Co., Ltd (hereinafter, the “Operator”).
1.1. The Operator’s primary goal and condition for carrying out its activities is the observance of human and civil rights and freedoms when processing personal data, including protection of the rights to privacy, personal and family secrets.
1.2. This Policy of the Operator regarding personal data processing (hereinafter, the “Policy”) applies to all information that the Operator may receive about visitors to the website https://bikephuket.com.
2. Basic Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computer equipment.
2.2. Blocking of personal data — temporary cessation of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and information materials, as well as software and databases that ensure their availability on the Internet at https://bikephuket.com.
2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Depersonalization (anonymization) of personal data — actions resulting in the impossibility, without additional information, of determining whether personal data belong to a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal or natural person that independently or jointly with other persons organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://bikephuket.com.
2.9. Personal data permitted by the personal data subject for dissemination — personal data to which an unlimited number of persons are granted access by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter, “personal data permitted for dissemination”).
2.10. User — any visitor to the website https://bikephuket.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or making personal data available to an unlimited circle of persons, including the publication of personal data in the media, placement in information and telecommunication networks, or otherwise providing access to personal data.
2.13. Cross-border transfer of personal data — 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.
2.14. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed with no possibility of further restoration of the personal data content in the personal data information system and/or physical media of personal data are destroyed.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject reliable information and/or documents containing personal data;
— in the event the personal data subject withdraws consent to the processing of personal data and/or sends a request to cease personal data processing, continue processing personal data without the personal data subject’s consent where grounds specified in the Personal Data Law exist;
— independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations provided for by the Personal Data Law and the regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information regarding the processing of his/her personal data;
— organize personal data processing in the manner established by applicable legislation of the Russian Federation;
— respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, upon its request, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Policy concerning personal data processing;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to personal data;
— cease the transfer (dissemination, provision, access), cease processing, and destroy personal data in the manner and in cases provided for by the Personal Data Law;
— perform other duties provided for by the Personal Data Law.
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the Operator clarify (update, modify) their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— stipulate the condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to personal data processing and demand cessation of personal data processing;
— appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.
5.3. Combining databases containing personal data, the processing of which is carried out for mutually incompatible purposes, is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed must correspond to the stated purposes of processing. Excessive personal data processing relative to the stated purposes is not permitted.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures that incomplete or inaccurate data are deleted or clarified.
5.7. Personal data are stored in a form allowing identification of the personal data subject no longer than required by the purposes of personal data processing, unless the period for storing personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or surety. Processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or if there is no longer a need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing
conclusion, performance, and termination of civil-law contracts
Personal data
— surname, first name, patronymic
— email address
— phone numbers
Legal grounds
— the Operator’s charter (founding) documents
Types of personal data processing
Collection, recording, systematization, accumulation, storage, destruction, and depersonalization (anonymization) of personal data.
7. Conditions for Processing Personal Data
7.1. Personal data are processed with the consent of the personal data subject to the processing of his/her personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for the administration of justice, the execution of a court judgment, or an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of a contract to which the personal data subject is a party, a beneficiary, or a surety, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or a surety.
7.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not thereby infringed.
7.6. Processing is carried out with respect to personal data made accessible to an unlimited number of persons by the personal data subject or at his/her request (hereinafter, “publicly available personal data”).
7.7. Processing is carried out with respect to personal data subject to publication or mandatory disclosure under federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures necessary to fully meet the requirements of applicable personal data protection laws.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil-law contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending the Operator a notice to the Operator’s email address bikephuket@gmail.com with the note “Update of personal data”.
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or applicable law. The User may withdraw his/her consent to the processing of personal data at any time by sending the Operator a notice by email to bikephuket@gmail.com with the note “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such parties (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. [source text appears incomplete] The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on transfer (other than granting access), as well as on processing or processing conditions (other than obtaining access) of personal data permitted for dissemination, do not apply where personal data are processed in state, public, or other public interests as defined by the legislation of the Russian Federation.
8.7. In processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or surety.
8.9. Grounds for terminating personal data processing may include achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a demand to cease personal data processing, as well as detection of unlawful processing of personal data.
9. List of Actions the Operator Performs with the Received Personal Data
9.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the information obtained via information and telecommunication networks or without such networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the appropriate information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on matters concerning the processing of his/her personal data by contacting the Operator via email at bikephuket@gmail.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid for an indefinite period until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://bikephuket.com/privacy/