This Personal Data Privacy Policy (hereinafter referred to as the Privacy Policy) was developed in accordance with the provisions of the Constitution of the Russian Federation, Federal Law dated July 27, 2006 N 149-FZ "On information, information technologies and information protection", Federal Law dated July 27, 2006 N 152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data) and other regulatory legal acts in the field of protection and processing of personal data in force in the Russian Federation and refers to the site located at: https:// promotion.a-club.ru/ (hereinafter referred to as the Website).

Use of the Site’s services means the User’s unconditional consent to this Policy and the conditions for processing his personal information specified therein; in case of disagreement with these conditions, the User must refrain from using the services.

The following terms are used in this Privacy Policy:

• A website is an interactive set of pages located on the domain name https://promotion.a-club.ru/ ;

• Site user - an individual, user of site services, subject of personal data who voluntarily registered on the site and provided the necessary personal data upon registration;

• Personal data - any information relating to a directly or indirectly identified or identifiable individual (subject of personal data), including persons indicated by the User and who are beneficiaries under the Agreement for tourist services; personal information that the User provides about himself independently during registration (creating an account) or in the process of using the Services, including personal data of the User and other persons specified by the User; data that is automatically transferred to the Site services during their use using software installed on the User’s device, including IP address, cookie data, information about the User’s browser (or other program through which services are accessed), technical characteristics of the equipment and software used by the User, date and time of access to services, addresses of requested pages and other similar information.

• Processing of personal data - any action (operation) or set of actions (operations) performed using automation tools or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data, as well as carrying out any other actions provided for by the current legislation of the Russian Federation, using automation tools, including in information and telecommunication networks, or without using such funds, as well as for the transfer (including cross-border) of this personal data to the Tour Operator and third parties (service providers included in the tourism product). The processing of personal data is carried out by the Travel Agency, Tour Operator and direct service providers (including for the purpose of issuing travel documents, booking at accommodation facilities and with carriers, insuring all persons specified in the Application, transferring data to the consulate of a foreign state, resolving claims issues when their occurrence).

1. GENERAL PROVISIONS

1.1. Within the framework of this Policy, the User’s personal information means:

1.1.1. Personal information that the User provides about himself independently in the process of using the services, including the User’s personal data. Information required for the provision of services is marked in a special way.

1.1.2. Data that is automatically transferred to the Site services during their use using software installed on the User’s device, including IP address, cookie data, information about the User’s browser (or other program through which services are accessed), technical characteristics of the equipment and software used by the User, date and time of access to services, addresses of requested pages and other similar information.

1.1.3. This Privacy Policy applies only to the Site https://promotion.a-club.ru/ . The site https://promotion.a-club.ru/ does not control and is not responsible for third party sites that the User can go to via links available on the Site https://promotion.a-club.ru/ .

2. PURPOSES OF PROCESSING USERS’ PERSONAL INFORMATION

2.1. The site collects and stores only that personal information that is necessary to provide services or fulfill agreements and contracts with the User, except in cases where the law provides for mandatory storage of personal information for a period specified by law.

If a notification is received from the User about the withdrawal of consent to the processing of personal data, the Site stops processing the User’s personal data within a period not exceeding 10 business days from the date of receipt.

Notification of withdrawal of consent to the processing of personal data is sent to the email address: promotion@a-club.ru

2.2. The Site processes the User’s personal information for the following purposes:

2.2.1. Identification of the User registered on the Site;

2.2.2. Conclusion, execution and termination of civil contracts with individuals, legal entities, individual entrepreneurs and other persons in cases provided for by the legislation of the Russian Federation and the Charter of the Company.

2.2.3.  Establishing feedback with the User, including sending notifications, requests regarding the use of the Site, provision of services, processing requests and applications from the User.

2.2.4.  Any contacts with the User through the communication channels specified by him, including for analytics of an individual’s actions on the website, processing incoming requests, sending information about the Company’s products and services, fulfilling the terms of contracts (to which the subject of personal data is or will be a party),

3. CONDITIONS FOR PROCESSING USERS’ PERSONAL INFORMATION AND ITS TRANSFER TO THIRD PARTIES

3.1. The site stores personal information of Users in accordance with the internal regulations of specific services.

3.2. The site has the right to transfer the User’s personal information to third parties in the following cases:

• l The user has expressed consent to such actions;

• l The transfer is necessary for the User to use a certain service or to fulfill an agreement with the User;

• l The transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law;

3. 4. In case of loss or disclosure of personal data, the Company informs the User about the loss or disclosure of personal data.

3.5. The Company takes the necessary organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.

3.6. The Company, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.

4. OBLIGATIONS OF THE PARTIES

4.1. The user is obliged:

• l Provide information about personal data necessary to use the Site;

• l Update, supplement the provided information about personal data in case of changes in this information and necessary for the execution of the Agreement.

4.2. The society is obliged:

• l Use the information received solely for the purposes specified in this Privacy Policy;

• l Ensure that confidential information is kept secret, not disclosed without the prior written permission of the User, and also not sell, exchange, publish or disclose in other possible ways the User’s personal data transferred, except as provided for in this Privacy Policy;

• l To ensure the protection of the User's personal data during their processing, the following legal, organizational and technical measures have been taken against unauthorized, unlawful or accidental access to personal data, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful actions in relation to personal data;

• l Block personal data relating to the relevant User from the moment of application or request from the User or his legal representative or the authorized body for the protection of the rights of personal data subjects for the period of verification in the event of detection of unreliable personal data or unlawful actions.

5. RESPONSIBILITY OF THE PARTIES

5.1. The Company, which has not fulfilled its obligations, is liable for losses incurred by the User in connection with the unlawful use of personal data, in accordance with the legislation of the Russian Federation.

5.2. In the event of loss or disclosure of confidential information, the Company shall not be liable if this confidential information:

• l Became public property before its loss or disclosure;

• l Was received from a third party prior to its receipt by the Site Administration

• l Was disclosed with the consent of the User.

6. DISPUTE RESOLUTION

6.1. Before filing a claim in court regarding disputes arising from the relationship between the Site User and the Company, it is mandatory to submit a claim (a written proposal for a voluntary settlement of the dispute).

6.2. The recipient of the claim within 10 calendar days from the date of receipt of the claim notifies the claimant in writing of the results of consideration of the claim. If no agreement is reached, the dispute will be referred to the court in accordance with the current legislation of the Russian Federation.

6.3. The current legislation of the Russian Federation applies to this Privacy Policy and the relationship between the User and the Site Administration.

7. ADDITIONAL CONDITIONS

7.1. The Site Administration has the right to make changes to this Privacy Policy without the User’s consent.

7.2. The new Privacy Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new edition of the Privacy Policy.

7.3. All suggestions or questions regarding this Privacy Policy should be reported to the email address: promotion@a-club.ru 

7.4. The current Privacy Policy is posted on the page at:https://promotion.a-club.ru/ ;

7.5. This Privacy Policy is an integral part of the Public Offer and the Agreement for the use of the Site, posted on the page at: https://promotion.a-club.ru/ .

Moscow "__" May 2024

1. General Provisions

1.1. This User Agreement (hereinafter referred to as the Agreement) applies to the website located at https://promotion.a-clu b.ru/ (hereinafter referred to as the Site).

1.2. User of the Site (hereinafter referred to as the User) is a person who has access to the Site via the Internet and uses the Site.

1.3. Content of the Site (hereinafter referred to as the Content) - protected results of intellectual activity, including annotations, articles, illustrations, covers, graphic, text, photographic, derivatives, composite and other works, user interfaces, visual interfaces, trademark names, logos, computer programs , databases, as well as the design, structure, selection, coordination, appearance, general style and arrangement of this Content included in the Site and other intellectual property objects collectively and/or individually contained on the Site.

1.4. This Agreement governs the relationship between the Site Administration and the User of this Site.

1.5. The Site Administration reserves the right to change, add or delete clauses of this Agreement at any time without notifying the User.

1.6. The subject of this Agreement is to provide the User with access to the services contained on the Site.

2. Terms of use of the Site

2.1. The use of materials and services of the Site is regulated by the current legislation of the Russian Federation.

2.2. Continued use of the Site by the User means acceptance of the Agreement and the changes made to this Agreement.

2.3. The User is personally responsible for checking this Agreement for changes to it.

2.4. The user agrees not to take actions or leave comments or entries that may be considered to violate Russian legislation or international law, including in the field of intellectual property, copyright and/or related rights, generally accepted norms of morality and morality, as well as any actions which lead or may lead to disruption of the normal operation of the Site and Site services.

2.5. The content of the Site cannot be copied, published, reproduced, transmitted or distributed in any way, or posted on the global Internet without the prior written consent of the Site Administration. For violation of this norm, the User is responsible in accordance with the current legislation of the Russian Federation.

2.6. When quoting materials from the Site, including protected copyright works, a link to the Site is required.

2.7. The Site Administration is not responsible for visiting and using external resources, links to which may be contained on the Site.

2.8. The Site Administration is not responsible and has no direct or indirect obligations to the User in connection with any possible or occurred losses or damages associated with any content of the Site, copyright registration and information about such registration, goods or services available on or received through external sites or resources or other contacts of the User that he entered into using information posted on the Site or links to external resources.

3. Other conditions

3.1. All possible disputes arising from or related to this Agreement shall be resolved in accordance with the current legislation of the Russian Federation.

3.2. The recognition by a court of any provision of the Agreement as invalid or unenforceable does not entail the invalidity of other provisions of the Agreement.

3.3. Inaction on the part of the Site Administration in the event of a violation by any of the Users of the provisions of the Agreement does not deprive the Site Administration of the right to later take appropriate actions to protect its interests and protect copyrights on Site materials protected in accordance with the law.