1. General

1.1. These Confidentiality Policy, hereinafter referred to as «Policy», is the set of standards regulating policy applicable by NAJET Limited Liability Company (Main State Registration No 5177746120250), hereinafter referred to as «Operator», to processing of personal data obtained within operation of http://www.najet.ru Web site, hereinafter referred to as «Site», and services of the Site.

1.2. Unless otherwise stated herein, terms usable in the Policy have the same meaning as that specified in Federal Law No 152-FZ dated 27.07.2006, titled: «On Personal Data». For purposes of the Policy, the term «User» means any person using the Site and its services, and also any other persons, on behalf of or in the interests of whom the User (directly or indirectly):
— uses the Site and its services, and/or;
— selects and makes orders for any products and services with use of the Site and its services, and/or;
— whose personal data are provided by the User in the use of the Site and its services

1.3. Any procedures performed by the User within uses of the Site and its services, including in those performed any part thereof, means:
— full and unconditional acceptance by the User of all provisions of the Policy, in full, without any reservations or exceptions, and;
— informed consent provided by him for processing of his own personal data and for that of any personal data provided by him, as specified in the Policy.
In case of any disagreement with the Policy, the User should refrain from any use of the Site and its services.

1.4. The User should:
— provide accurate personal data only when using the Site and its services;
— in case of any change in any data provided hereunder, update and remove them;
— as far as any third party personal data provided by him are concerned, provide and guarantee lawful nature for obtaining and for having consent from third parties concerned for provision of their personal data to the Operator, and also for processing of their personal data along with personal data of the User, consistently with this Policy

1.5. The User may:
— obtain any information regarding processing of his personal data;
— require updating for, blocking or deletion of any of his personal data in case such data are incomplete, obsolete, inaccurate or obtained in violation of the applicable laws

1.6. The Operator should:
— process any personal data obtained hereunder for no purposes other than personal data collection purposes specified in Policy

1.7. The Operator may:
— process any personal data obtained consistently with the Policy

1.8. The Operator has no control of and bears no responsibilities for processing of any personal data contained at any third party sites the User may go to via any links available on the Site or within use of services of the Site. Among other things, the Operator has no control of and bears no responsibilities for processing of any personal data provided in connection with uses of such third party sites.

2. Personal Data Collection Purposes

2.1. Purposes of personal data collection hereunder are:
— maintaining operability of the Site and its services; provision of such services;
— identification of the User and maintaining communication with him;
— fulfillment of commitments towards the User and towards airlines involved in sales (provision) of and payments for any products and services selected by the User with use of the Site and its services;
— ensuring sales (provision) of and payments for any products and services selected by the User with use of the Site and its services;
— settlement of any disputes that may arise in connection with use of the Site and its services, and also in connection with sales (provision) of and payments for any products and services selected by the User with use of the Site and its services;
— advertisement activities;
— statistical and any other surveys based on de-personalized data

3. Legal Basis for Personal Data Processing

3.1. Legal basis for personal data processing hereunder is made up of the applicable set of Russian laws regulating mutual relationships arising within personal data processing, this Policy, and also agreements entered into between the Operator and the User in connection with use of the Site and its services.

4. Amounts and Classes of Personal Data to Be Processed; Personal Data Subject Classes

4.1. Personal data hereunder are processed by the Operator in amounts required for purposes stated for collection of such personal data. For these purposes, the Operator processes all and any information related, directly or indirectly, to the User, including his surname, name and patronymic, telephone number, address, personal identify document, payment funds and bank accounts.

4.2. The Operator processes all and any information, which is:
— provided by the User in connection with use of the Site and its services;
— available for automated delivery to the Site and its services in the course of their uses (IP address, cookie information, information about the User’s browser, etc.);
— obtained by the Operator from any airlines or any other parties involved in sales (provision) of and payments for any products and services selected by the User with use of the Site and its services

4.3. The term «Personal data subject classes» means, among others:
— Users and any other customers and contracting parties (who are individuals) of the Operator;
— representatives of Users and other customers and contracting parties of the Operator;
— individuals, on behalf and/or in the interests of whom Users make uses of the Site and its services, and also select and make orders for any products and services;
— individuals, whose personal data are provided by the Users within uses of the Site and its services

5. Personal Data Processing Methods and Terms

5.1. The Operator complies with all standards bindingly required by the Russian laws for provision of confidentiality and security for any personal data that may be processed by the Operator hereunder.

5.2. Personal data may be processed without any restrictions in terms of the applicable dates, in any way consistent with the applicable laws, including use of any automated equipment (or without use of any such equipment), by way of any procedures specified in Federal Law No 152-FZ dated 27.07.2006, titled: «On Personal Data», including any trans-border personal data transmissions.

5.3. The Operator may provide any personal data to any third parties only in case the User expressly states his consent for such provision. Furthermore, the Operator may, without having to obtain the User’s consent for this, provide any personal data to any third parties in case it is required for:
— provision of security for the User’s uses of the Site or any of its services;
— sales (provision) of and payments for any products and services selected by the User with use of the Site and its services;
— maintaining of compliance with requirements applicable by governmental authorities, governmental agencies and local self-government authorities, in correspondence with applicable Russian laws and any other applicable laws;
— protection of the rights and the legislatively protected interests of the Operator or those of any third parties, in case, among other things, the User is in default of his responsibilities and/or terms of use of the Site and its services. In case of any such provision of personal data to any third parties, such third parties may also, along with the Operator, process personal data so obtained.

5.4. Processing of any personal data should be terminated in case personal data subject concerned revokes his consent for processing of his personal data, or in case it is found that any personal data are processed in an unauthorized way.

5.5. In case it is proved that any personal data are inaccurate, or that they are processed in an unauthorized way, such personal data should be updated or deleted, and, correspondingly, their processing should be terminated.

6. Other

6.1. The Operator may, at any time, if he thinks it fit and without resorting to any courts, change the Policy by way of notification posted to this effect on the Site or by way of the Policy appropriately replaced on the Site. The Policy in its wording so updated should be posted on the Site at: https://najet.ru/en/policy.html

6.2. All proposals and questions, if any, related to the Policy may be sent to the Operator to: info@najet.ru

6.3. All mutual relationships related to the Policy in any way shall be regulated by no laws other than those applicable in the Russian Federation.