Approved
General Director of LLC “Sai-Khonash Travel” E.V. Saryglar
Posted and last updated on the website: 29 May 2025
1.1. This Personal Data Processing Policy (hereinafter—the “Policy”) is intended to protect the rights and freedoms of individuals whose personal data are processed by Limited Liability Company “Sai-Khonash Travel” (hereinafter—the “Operator”).
1.2. The Policy has been developed pursuant to paragraph 2, part 1, article 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter—the “Personal Data Law”) and is published on the Operator’s website at www.tuva-travel.com, where it is freely accessible.
1.3. The Policy contains the information subject to disclosure under part 1, article 14 of the Personal Data Law and is a publicly available document.
2.1. The Operator conducts its business at the following address: 14 Udachnyi Avenue, SNT Udachnoe, Kyzyl, 667002, Russian Federation.
3.1. The Operator processes personal data on a lawful and fair basis for the purposes of performing the functions, powers and duties imposed by law, and for exercising the legitimate rights and interests of the Operator, its employees and third parties.
3.2. Personal data are obtained by the Operator directly from the personal-data subjects (hereinafter—“PD Subjects”).
3.3. Personal data are processed by automated and non-automated means, with or without the use of computer technology.
3.4. Processing activities include collection, recording, systematisation, accumulation, storage, updating (renewal, modification), retrieval, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction.
4.1. The Operator processes personal data of clients within civil-law relations governed by Part Two of the Civil Code of the Russian Federation of 26 January 1996 No. 14-FZ (hereinafter—“Clients”).
4.2. Clients’ personal data are processed in order to comply with Russian legislation and, in particular, to:
• receive enquiries and requests from PD Subjects;
• inform them about new products, special promotions and offers;
• conclude and perform contracts.
4.3. Processing is carried out with the Clients’ consent, given by the Clients and/or their legal representatives through conclusive actions on this website including, but not limited to, placing an order, registering a personal account or subscribing to a mailing list, in accordance with this Policy.
4.4. Personal data are retained no longer than necessary for the purposes of processing unless a longer period is required by Russian law.
4.5. The Operator may process the following personal data of Clients:
• Surname, first name, patronymic;
• Date of birth;
• Passport details;
• Address;
• Contact telephone number;
• E-mail address.
4.6. The Operator does not process special categories of personal data relating to:
• racial or ethnic origin;
• political opinions, religious or philosophical beliefs;
• health or sex life.
5.1. When processing personal data, the Operator takes—or ensures the taking of—legal, organisational and technical measures to protect personal data against unauthorised or accidental access, destruction, alteration, blocking, copying, provision, dissemination and any other unlawful actions.
5.2. These measures are planned and implemented to meet the requirements of article 19 of the Personal Data Law.
5.3. Under article 18.1 of the Personal Data Law, the Operator independently determines the scope of measures necessary and sufficient to ensure compliance with the legislation.
The Operator has, in particular, adopted the following measures:
• appointed a person responsible for organising personal-data processing;
• developed and implemented internal regulations governing personal-data processing and procedures for preventing, detecting and remedying violations;
• applied legal, organisational and technical measures to ensure personal-data security in accordance with article 19 of the Personal Data Law;
• established internal control over compliance with the Personal Data Law, subordinate regulations, personal-data protection requirements, this Policy and other internal documents;
• assessed the potential harm to PD Subjects from violations of the Personal Data Law and correlated that harm with the measures taken;
• ensured that employees directly involved in personal-data processing are familiar with Russian personal-data legislation, protection requirements, this Policy and the Operator’s internal regulations.
7.1. A PD Subject has the right to:
• obtain his or her personal data and information on their processing;
• request rectification, blocking or destruction of personal data that are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purpose;
• withdraw consent to personal-data processing;
• protect his or her rights and lawful interests, including recovery of losses and compensation for moral harm through the courts;
• appeal against acts or omissions of the Operator to the authorised body for the protection of personal-data subjects’ rights or to a court.
7.2. To exercise these rights and interests, a PD Subject may contact the Operator in person or through a representative. A request must contain the information specified in part 3, article 14 of the Personal Data Law.
General Director of LLC “Sai-Khonash Travel” ________________ (E. V. Saryglar)
