Personal Data Processing Policy

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by YDM "Tourist Support Center" (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of a person and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator policy on the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website https://www.ydmturk.com.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data is the processing of personal data using computer technology.

2.2. Blocking of personal data — temporary cessation of processing of personal data (except for cases when processing is necessary to clarify personal data).

2.3. Website — a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://www.ydmturk.com.

2.4. Personal data information system — a set of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data — actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data by a specific User or another subject of personal data.

2.6. Personal data processing — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.

2.8. Personal data — any information related directly or indirectly to a specific or determinable User of the website https://www.ydmturk.com.

2.9. Personal data permitted for distribution by the personal data subject — personal data, access to which by an unlimited number of persons is granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner prescribed by the Personal Data Law (hereinafter — personal data permitted for distribution).

2.10. User — any visitor to the website https://www.ydmturk.com.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an unlimited number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including disclosure of personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign government body, foreign individual or foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of tangible media of personal data.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:

— receive reliable information and/or documents containing personal data from the personal data subject;

— if the personal data subject revokes consent to the processing of personal data, or sends an application with a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;

— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— provide the personal data subject, at his request, with information regarding the processing of his personal data;

— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;

— respond to requests and inquiries of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

— notify the authorized body for the protection of the rights of personal data subjects, upon request of such body, of the necessary information within 10 days from the date of receipt of such request;

— publish or otherwise provide unlimited access to this Policy regarding the processing of personal data;

— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;

— fulfill other obligations stipulated by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

— receive information regarding the processing of their personal data, except for cases stipulated by federal laws. The information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data related to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;

— demand that the operator clarify his personal data, block or destroy it if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, and also take measures provided for by law to protect their rights;

— put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;

— to revoke consent to the processing of personal data, as well as to send a request to terminate the processing of personal data;

— appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or inaction of the Operator when processing his personal data;

— to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:

— provide the Operator with reliable data about themselves;

— notify the Operator about clarification (update, change) of their personal data.

4.3. Persons who have transferred to the Operator false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data shall be processed on a lawful and fair basis.

5.2. Personal data shall be limited to achieving specific, predetermined and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data shall not be permitted.

5.3. Combining databases containing personal data that are processed for purposes that are incompatible with each other shall not be permitted.

5.4. Only personal data that meet the purposes of their processing shall be processed.

5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of their processing shall not be permitted.

5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data shall be ensured. The Operator shall take the necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that allows the personal data subject to be identified, for no longer than required for the purposes of personal data processing, unless the storage period for personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor. The processed personal data shall be destroyed or depersonalized upon achieving the processing purposes or in the event of loss of the need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of personal data processing

Purpose of processing informing the User by sending e-mails

Personal data • last name, first name, patronymic

• e-mail address

• telephone numbers

Legal grounds • statutory (constituent) documents of the Operator

• agreements concluded between the operator and the personal data subject

Types of personal data processing • Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

• Sending informational letters to an e-mail address

7. Terms of personal data processing

7.1. Personal data shall be processed with the consent of the personal data subject to the processing of his personal data.

7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to exercise the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of an agreement to which the subject of personal data is a party, beneficiary or guarantor, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

7.6. The processing of personal data is carried out, access to which by an unlimited number of persons is provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).

7.7. The processing of personal data is carried out that is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for collecting, storing, transferring and other types of processing personal data

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.

8.3. In the event that inaccuracies are detected in the personal data, the User can update them independently by sending the Operator a notification to the Operator's e-mail address info@tscturk.com with the subject line "Updating personal data".

8.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the agreement or applicable law.

The User may revoke their consent to the processing of personal data at any time by sending the Operator a notice via e-mail to the Operator's e-mail address info@tscturk.com with the subject "Revocation of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. Subject of personal data and/or with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

8.6. The prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, shall not apply in cases of processing personal data in the state, public and other public interests determined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing personal data.

8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, an agreement to which the personal data subject is a party, beneficiary or guarantor.

8.9. The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiration of the consent of the personal data subject, withdrawal of consent by the personal data subject or a requirement to terminate the processing of personal data, as well as the identification of unlawful processing of personal data.

9. List of actions performed by the Operator with the received personal data

9.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.

9.2. The operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunications networks.

10. Cross-border transfer of personal data

10.1. Before commencing activities on the cross-border transfer of personal data, the operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data).

10.2. Before submitting the above notification, the operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the subject of the personal data, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail at info@tscturk.com.

12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is freely available on the Internet at https://ydmturk.com/privacy1-en.php.