1. General Provisions

1.1. This Policy sets out the procedures for processing and protecting the personal data of visitors to https://aelita-hotel.com/, the website of the Aelita Hotel (the “Website”).

1.2. The personal data operator is Individual Entrepreneur Aleksandr Viktorovich Safronov, Taxpayer Identification Number (INN): 591105282644 (the “Operator”).

Hotel address: 116a Pyatiletki Street, Berezniki, Perm Krai, Russia.

Email for enquiries concerning personal data processing: reception@aelita-hotel.com.

1.3. This Policy applies to the processing of personal data when using the Website, submitting enquiries, requesting a promotional code, communicating through the online chat and booking accommodation.

1.4. Personal data processing is governed by Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other applicable laws and regulations of the Russian Federation.

1.5. This Policy is an informational document. Visiting the Website and reading this Policy do not, in themselves, constitute consent to personal data processing where such consent is required.

2. Purposes of Processing and Categories of Personal Data

2.1. Handling enquiries submitted through the “Ask a Question” form.

When a visitor completes the form, the Operator processes the name, email address and message content provided by the visitor.

The data is used to review the enquiry, clarify relevant details and provide a response.

The hotel’s contact email address is reception@aelita-hotel.com.

2.2. Obtaining a promotional code.

The Website provides a form through which visitors can request a promotional code for a discount on accommodation bookings.

When this form is completed, the visitor’s email address is processed. The data is used to fulfil the request and send an email containing the promotional code and its terms of use.

Requesting a promotional code does not, in itself, constitute a subscription to subsequent marketing communications or authorise the use of the email address for other purposes.

The discount amount, redemption procedure and other terms of the offer are specified in the relevant form and the email containing the promotional code.

2.3. Communication through the online chat.

The Jivo service is used to assist visitors. When a visitor uses the chat, the content of the correspondence and the contact details voluntarily provided by the visitor are processed.

Depending on the service features used, technical information about the visitor’s device and visit to the Website may also be processed.

The purpose of processing is to provide information about accommodation and hotel services, handle enquiries and arrange follow-up communication.

2.4. Accommodation bookings.

The TravelLine booking module is used to make reservations.

Depending on the booking process selected and the fields completed, the following data is processed:

• surname, first name and patronymic;
• telephone number;
• email address;
• citizenship;
• details of the customer and the main guest when booking for another person;
• check-in and check-out dates and selected times;
• number of adults and children, and children’s ages where provided when selecting accommodation;
• selected room category, rate plan and additional services;
• booking comments, if provided;
• promotional code, if provided;
• selected payment method and information about the reservation’s payment status.

The data is used to create, confirm, modify and cancel reservations, communicate with the customer, and enter into and perform a contract.

If a visitor chooses to sign in through an external service, data may be transferred to the booking module in accordance with the permissions granted by the visitor to that service.

For online payments, bank card details are entered and payments are processed on the payment service’s secure page. The processing of payment data is also governed by the documents of the relevant payment service provider.

2.5. Website operation and analytics.

Yandex Metrica and the integrated Google Analytics tools are used to analyse traffic and improve the Website.

Depending on the settings and the service features actually operating, the following may be processed: IP address, information about the visitor’s device and browser, referral source, pages viewed, time of visit and actions on the Website, as well as cookie identifiers.

This information is used to compile statistical reports, identify technical errors and assess the Website’s usability.

2.6. Informational and promotional communications.

Responses to enquiries, booking confirmations and other messages necessary to fulfil a visitor’s request or perform a contract are sent for the relevant processing purpose.

An email containing a promotional code is sent at the visitor’s request. If the message constitutes advertising, it is sent only with prior consent to receive advertising.

Subsequent special offers, news and other promotional messages may be sent only with the visitor’s separate consent. Consent to personal data processing does not, in itself, replace consent to receive advertising.

Visitors may opt out of promotional messages by contacting reception@aelita-hotel.com or using the opt-out method specified in the message, where available. Upon receiving such a request, the Operator ceases sending advertising to the recipient concerned.

2.7. Feedback forms, the promotional code request form and the online chat are not intended for submitting passport details, health information or other information unnecessary for the relevant purpose. Visitors should avoid including excessive personal data in their messages.

3. Legal Grounds for Processing

3.1. Depending on its purpose, personal data processing is based on:

• the visitor’s consent to personal data processing;
• the need to enter into a contract at the visitor’s initiative or to perform a contract;
• compliance with obligations established by the laws of the Russian Federation;
• the exercise of the Operator’s rights and legitimate interests, provided that the rights and freedoms of the personal data subject are respected.

3.2. Data used to respond to a general enquiry or fulfil a promotional code request is processed on the basis of the visitor’s consent and within the scope of the relevant purpose.

If an enquiry concerns entering into or performing a contract, the data necessary for that purpose may be processed on the relevant contractual basis.

3.3. Personal data processing through analytics tools is carried out where the necessary legal basis exists, including the visitor’s consent where required.

3.4. Contact details used to send promotional offers are processed on the basis of the relevant consent. Sending advertising requires the recipient’s prior consent in accordance with the advertising laws of the Russian Federation.

4. Processing Procedures and Third-Party Services

4.1. The Operator processes personal data using automated means and, where necessary, non-automated means.

4.2. Processing may include the collection, recording, organisation, accumulation, storage, updating, retrieval, use, provision of access, blocking, deletion and destruction of personal data.

4.3. The following services are used to operate the Website and assist visitors:

• Jivo — communication with visitors;
• TravelLine — accommodation bookings and display of the hotel’s rating and reviews;
• Yandex Metrica and Google Analytics tools — analysis of Website traffic and usage;
• Yandex Maps — display of the hotel’s location;
• World Weather — display of weather information.

Hosting and email services are also used to host the Website, operate forms and deliver messages.

4.4. When external components are loaded, their providers may receive technical information necessary to deliver the relevant component, including the visitor’s IP address and browser information.

Processing is carried out subject to applicable laws, contracts, terms of use and the privacy policies of the respective services.

4.5. The use of Google Analytics and other foreign services may involve transferring data for processing outside the Russian Federation. When making cross-border transfers, the Operator must comply with the requirements of the laws of the Russian Federation.

4.6. Access to personal data by the Operator’s employees is limited to what is necessary for the performance of their duties.

4.7. If personal data processing is entrusted to another party, the terms of that arrangement are determined in accordance with the laws of the Russian Federation. Engaging a service provider does not relieve the Operator of its statutory obligations towards personal data subjects.

4.8. Personal data contained in enquiries and the promotional code request form is not intended for public disclosure. Data is provided to public authorities where there are legal grounds for doing so.

4.9. The Website may contain links to other websites and services, including those related to transfers and visa support. Before submitting data through such resources, visitors should read the personal data processing terms published there. This Policy does not replace the documents of the independent operators of those resources.

5. Use of Cookies

5.1. The Website and connected services may use cookies and similar technologies to enable certain features, save preferences and analyse traffic.

5.2. Cookies are small pieces of data stored on a visitor’s device and used when interacting with the Website.

5.3. Visitors may restrict the use of cookies or delete them through their browser settings. Such restrictions may affect the operation of certain Website features.

5.4. Deleting cookies from a device does not delete information previously stored in the information systems of the Operator or service providers. Visitors may contact reception@aelita-hotel.com with questions about the processing of such data.

6. Retention and Deletion of Personal Data

6.1. Enquiries received by email and correspondence in Jivo are retained without a predetermined end date. The Operator does not carry out scheduled deletion of correspondence.

6.2. An email address provided to obtain a promotional code is processed to fulfil the relevant request. Once this purpose has been achieved, the data must be destroyed in accordance with the procedures and time limits established by the laws of the Russian Federation, unless another legal basis for continued processing exists.

If the visitor has separately consented to receive subsequent promotional messages, processing for that purpose is carried out within the scope of the relevant consent.

6.3. Booking-related data is processed for the period necessary to enter into and perform a contract and to comply with statutory obligations. Further retention is permitted where an appropriate legal basis exists.

6.4. Visitors may request the deletion of their personal data by contacting reception@aelita-hotel.com.

6.5. The Operator reviews the request and determines whether deletion is possible, taking into account any legal grounds for continued processing. If the data is necessary to perform a contract or comply with a statutory obligation, processing may continue to the extent necessary on the relevant legal basis.

6.6. When grounds for the destruction of data arise, the Operator deletes the data from the information systems in use or ensures that the engaged service provider destroys it in accordance with the procedure established by law.

7. Personal Data Protection

7.1. The Operator must take the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, disclosure, alteration, loss and destruction.

7.2. When organising processing activities, the Operator determines data access procedures, authorised persons and security measures, taking into account the nature of the data, the information systems used and legal requirements.

7.3. When engaging service providers, the Operator must ensure that the conditions for processing and protecting personal data required by law are met.

8. Visitors’ Rights

8.1. Visitors have the right to:

• obtain information about the processing of their personal data;
• request the correction of incomplete, outdated or inaccurate data;
• request the blocking or destruction of data in cases provided for by law;
• withdraw consent to personal data processing;
• request the termination of processing in cases provided for by law;
• opt out of promotional messages;
• seek protection of their rights by contacting Roskomnadzor or bringing proceedings before a court.

8.2. To exercise these rights, visitors may send a request to reception@aelita-hotel.com or to the hotel address specified in Section 1.

8.3. The request should state the action sought and provide information that enables the relevant correspondence, promotional code request or reservation to be located. Where necessary, the Operator may request information to verify the applicant’s identity or the authority of their representative.

8.4. Requests are reviewed within the time limits established by the laws of the Russian Federation.

8.5. Withdrawal of consent does not prevent continued processing of personal data where an independent legal basis exists.

9. Changes to This Policy

9.1. The current version of this Policy is available at https://aelita-hotel.com/privacy-policy/.

9.2. If the purposes of processing, the categories of personal data or the processing procedures change, the Operator updates this Policy and its revision date.