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1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the requirements of the Law “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken to ensure the security of personal data by MY HOLIDAY VACATION HOMES RENTAL L.L.C(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 rights to privacy, personal and family confidentiality, to be one of the primary objectives and essential conditions of its activities.
1.2. This Operator’s Personal Data Processing Policy (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://mymymy.group.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computing equipment.
2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify or update personal data.
2.3. Website means a collection of graphic and informational materials, as well as computer software and databases, ensuring their availability on the Internet at https://mymymy.group.
2.4. Personal data information system means a set of personal data contained in databases together with information technologies and technical means used for their processing.
2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belongs to a particular User or another personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, whether using automated means or without such means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator means a state authority, municipal authority, legal entity, or individual 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 categories of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://mymymy.group.
2.9. Personal data authorized by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been granted by the personal data subject by providing consent to the processing of personal data authorized for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorized for distribution”).
2.10. User means any visitor to the website https://mymymy.group.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of such personal data in the personal data information system, and/or resulting in the destruction of physical media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing personal data without the subject’s consent where grounds specified by the Personal Data Law exist;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and regulatory legal acts adopted pursuant thereto, 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 relating to the processing of their personal data;
— organize the processing of personal data in accordance with applicable legislation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized authority responsible for protecting the rights of personal data subjects, upon its request, with the required information within 10 days from the date such request is received;
— publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions involving personal data;
— discontinue the transfer (distribution, provision, access) and processing of personal data and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other obligations stipulated by the Personal Data Law.
4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator shall provide such information to the personal data subject in an accessible form, and such information shall not contain personal data relating to other personal data subjects unless there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data where such personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— require prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
— appeal unlawful actions or omissions of the Operator in connection with the processing of personal data to the authority responsible for protecting the rights of personal data subjects or through judicial proceedings;
— exercise other rights provided for by applicable legislation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification (update or modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent shall be liable in accordance with applicable legislation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing personal data in a manner incompatible with the purposes for which the personal data was collected is not permitted.
5.3. Databases containing personal data processed for incompatible purposes shall not be combined.
5.4. Only personal data relevant to the purposes of its processing shall be processed.
5.5. The content and scope of personal data processed shall correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, the accuracy and sufficiency of personal data and, where necessary, its relevance to the purposes of processing shall be ensured. The Operator shall take or ensure that necessary measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form allowing identification of the personal data subject for no longer than required for the purposes of processing, unless the retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Personal data being processed shall be destroyed or depersonalized once the purposes of processing have been achieved or when the need to achieve such purposes no longer exists, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
Providing information to the User by sending emails.
Personal data processed:
— surname, first name, patronymic;
— email address;
— telephone numbers.
Types of personal data processing:
— sending informational emails to the User’s email address.
7. Conditions for Processing Personal Data
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, or 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 or the enforcement of a judicial act or an act of another authority or official that is enforceable in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for exercising the rights and legitimate interests of the Operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data made accessible to an unlimited number of persons by the personal data subject or at their request is processed (hereinafter referred to as “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation governing personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except in cases related to compliance with applicable legislation 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 agreement.
8.3. If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator at info@mymymy.group with the subject line “Personal Data Update.”
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is established by an agreement or applicable legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification by email to the Operator at info@mymymy.group with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject and/or with the aforementioned documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, shall not apply where personal data is processed in state, public, or other public interests defined by applicable legislation.
8.7. The Operator shall ensure the confidentiality of personal data when processing it.
8.8. The Operator shall store personal data in a form allowing identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a personal data retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Personal data processing may be terminated upon achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of such consent by the personal data subject, submission of a request to terminate personal data processing, or identification of unlawful processing of personal data.
9. Actions Performed by the Operator with Personal Data Received
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of information via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized authority responsible for protecting the rights of personal data subjects of its intention to carry out such cross-border transfer. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above-mentioned notification, the Operator shall obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data shall not disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Operator’s Rights
The Operator has the right to send the User notifications about new products and services, special offers, and various events.
The User may unsubscribe from informational messages at any time by sending an email to the Operator at info@mymymy.group with the subject line “Unsubscribe from Notifications About New Products, Services, and Special Offers.”
13. Final Provisions
13.1. The User may obtain clarification on any matters relating to the processing of their personal data by contacting the Operator via email atinfo@mymymy.group.
13.2. Any amendments to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain in effect indefinitely until replaced by a new version.
13.3. The current version of the Policy is publicly available online at https://mymymy.group/privacy.
This Personal Data Processing Policy has been prepared in accordance with the requirements of the Law “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and sets out the procedure for processing personal data and the measures taken to ensure the security of personal data by MY HOLIDAY VACATION HOMES RENTAL L.L.C(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 rights to privacy, personal and family confidentiality, to be one of the primary objectives and essential conditions of its activities.
1.2. This Operator’s Personal Data Processing Policy (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://mymymy.group.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data means the processing of personal data using computing equipment.
2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify or update personal data.
2.3. Website means a collection of graphic and informational materials, as well as computer software and databases, ensuring their availability on the Internet at https://mymymy.group.
2.4. Personal data information system means a set of personal data contained in databases together with information technologies and technical means used for their processing.
2.5. Depersonalization of personal data means actions that make it impossible, without the use of additional information, to determine whether personal data belongs to a particular User or another personal data subject.
2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, whether using automated means or without such means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator means a state authority, municipal authority, legal entity, or individual 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 categories of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://mymymy.group.
2.9. Personal data authorized by the personal data subject for distribution means personal data to which access by an unlimited number of persons has been granted by the personal data subject by providing consent to the processing of personal data authorized for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorized for distribution”).
2.10. User means any visitor to the website https://mymymy.group.
2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data by any other means.
2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign government authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data means any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of such personal data in the personal data information system, and/or resulting in the destruction of physical media containing personal data.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
— obtain accurate information and/or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to the processing of personal data or submits a request to terminate the processing of personal data, continue processing personal data without the subject’s consent where grounds specified by the Personal Data Law exist;
— independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and regulatory legal acts adopted pursuant thereto, 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 relating to the processing of their personal data;
— organize the processing of personal data in accordance with applicable legislation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized authority responsible for protecting the rights of personal data subjects, upon its request, with the required information within 10 days from the date such request is received;
— publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions involving personal data;
— discontinue the transfer (distribution, provision, access) and processing of personal data and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other obligations stipulated by the Personal Data Law.
4. Key Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information concerning the processing of their personal data, except in cases provided for by federal laws. The Operator shall provide such information to the personal data subject in an accessible form, and such information shall not contain personal data relating to other personal data subjects unless there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data where such personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— require prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and submit a request to terminate the processing of personal data;
— appeal unlawful actions or omissions of the Operator in connection with the processing of personal data to the authority responsible for protecting the rights of personal data subjects or through judicial proceedings;
— exercise other rights provided for by applicable legislation.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any clarification (update or modification) of their personal data.
4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent shall be liable in accordance with applicable legislation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. Personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing personal data in a manner incompatible with the purposes for which the personal data was collected is not permitted.
5.3. Databases containing personal data processed for incompatible purposes shall not be combined.
5.4. Only personal data relevant to the purposes of its processing shall be processed.
5.5. The content and scope of personal data processed shall correspond to the stated purposes of processing. The processing of excessive personal data in relation to the stated purposes is not permitted.
5.6. When processing personal data, the accuracy and sufficiency of personal data and, where necessary, its relevance to the purposes of processing shall be ensured. The Operator shall take or ensure that necessary measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form allowing identification of the personal data subject for no longer than required for the purposes of processing, unless the retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Personal data being processed shall be destroyed or depersonalized once the purposes of processing have been achieved or when the need to achieve such purposes no longer exists, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing:
Providing information to the User by sending emails.
Personal data processed:
— surname, first name, patronymic;
— email address;
— telephone numbers.
Types of personal data processing:
— sending informational emails to the User’s email address.
7. Conditions for Processing Personal Data
7.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.
7.2. Personal data processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, or 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 or the enforcement of a judicial act or an act of another authority or official that is enforceable in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary for exercising the rights and legitimate interests of the Operator or third parties or for achieving socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data made accessible to an unlimited number of persons by the personal data subject or at their request is processed (hereinafter referred to as “publicly available personal data”).
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable legislation governing personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. Under no circumstances shall the User’s personal data be transferred to third parties, except in cases related to compliance with applicable legislation 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 agreement.
8.3. If inaccuracies in personal data are identified, the User may update such data independently by sending a notification to the Operator at info@mymymy.group with the subject line “Personal Data Update.”
8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is established by an agreement or applicable legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification by email to the Operator at info@mymymy.group with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication services, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject and/or with the aforementioned documents. The Operator shall not be liable for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data authorized for distribution, shall not apply where personal data is processed in state, public, or other public interests defined by applicable legislation.
8.7. The Operator shall ensure the confidentiality of personal data when processing it.
8.8. The Operator shall store personal data in a form allowing identification of the personal data subject for no longer than required by the purposes of personal data processing, unless a personal data retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Personal data processing may be terminated upon achievement of the purposes of processing, expiration of the personal data subject’s consent, withdrawal of such consent by the personal data subject, submission of a request to terminate personal data processing, or identification of unlawful processing of personal data.
9. Actions Performed by the Operator with Personal Data Received
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of information via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator shall notify the authorized authority responsible for protecting the rights of personal data subjects of its intention to carry out such cross-border transfer. Such notification shall be submitted separately from the notification of the intention to process personal data.
10.2. Before submitting the above-mentioned notification, the Operator shall obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data shall not disclose personal data to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
12. Operator’s Rights
The Operator has the right to send the User notifications about new products and services, special offers, and various events.
The User may unsubscribe from informational messages at any time by sending an email to the Operator at info@mymymy.group with the subject line “Unsubscribe from Notifications About New Products, Services, and Special Offers.”
13. Final Provisions
13.1. The User may obtain clarification on any matters relating to the processing of their personal data by contacting the Operator via email atinfo@mymymy.group.
13.2. Any amendments to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain in effect indefinitely until replaced by a new version.
13.3. The current version of the Policy is publicly available online at https://mymymy.group/privacy.