Documents

Accommodation Rules

I. General Provisions

  • 1.1. These Accommodation Rules have been developed in accordance with the Rules for the Provision of Hotel Services in the Russian Federation approved by Resolution of the Government of the Russian Federation dated 18 November 2020 No. 1853 (Moscow) “On Approval of the Rules for the Provision of Hotel Services in the Russian Federation” and the Law of the Russian Federation dated 07 February 1992 No. 2300-I “On Consumer Rights Protection”.
  • 1.2. These Rules regulate relations between consumers, i.e. individuals who intend to order or purchase or who order, purchase and/or use hotel services exclusively for personal or other needs not related to business activities; customers — individuals or legal entities who intend to order or purchase or who order or purchase hotel services under a hotel services agreement for the benefit of the consumer; and the service provider — the GRINN Hotel Complex (hereinafter — the Hotel Complex) located at 4 Kromskoye Highway, Orel.
  • 1.3. The Hotel Complex includes: GRINN Hotel 5* (Building I), GRINN “Business Class” Hotel 3* (Building II), and Orlovskoye Pomestye Eco-Hotel 3*. The room stock of GRINN Hotel 5* includes the following categories: “Presidential Suite”, “Suite”, “Lux”, “1st Category SINGLE”, “1st Category TWIN”. The room stock of GRINN “Business Class” Hotel 3* includes: “1st Category SINGLE”, “1st Category TWIN”. The room stock of Orlovskoye Pomestye Eco-Hotel 3* includes: “1st Category SINGLE” (27 m²), “1st Category SINGLE” (32 m²), “1st Category TWIN” (32 m²).

II. Booking of the Hotel Complex

  • 2.1. Bookings can be made in writing by e-mail, by fax, by phone, on the official website www.hotelgrinn.ru, or via third-party booking systems/tour operators that have contractual relations with the Hotel Complex.
  • 2.2. A booking is confirmed by sending a confirmation by e-mail or fax, or by communicating the booking number by phone.
  • 2.3. At their discretion, a guest may book a room with prepayment before check-in (guaranteed booking, see 2.6) or without prepayment (non-guaranteed booking, see 2.4).
  • 2.4. A non-guaranteed booking means the Hotel Complex holds the room until 18:00 local time on the scheduled arrival date. If the guest does not arrive by 18:00 local time, the booking is automatically canceled. The Hotel Complex’s obligations to accommodate cease, and accommodation is provided subject to availability on general terms.
  • 2.5. For a non-guaranteed booking, the first payment is made by the guest upon arrival at the front desk. A non-guaranteed booking is made after the guest receives a booking confirmation from the Hotel Complex without any financial guarantees from the guest. The confirmation must state the booking number, arrival terms and conditions, and a cost calculation for the ordered accommodation.
  • 2.6. No financial obligations arise between the Hotel Complex and the guest under a non-guaranteed booking.
  • 2.7. A guaranteed booking means the Hotel Complex holds the room until the check-out hour of the day following the scheduled arrival date. In case of late cancellation, late arrival, or no-show, the consumer or the customer is charged for actual room downtime (the bed in the room), but not more than one night. If the delay exceeds one day, the contract is terminated.
  • 2.8. A guaranteed booking creates full legal obligations between the Hotel Complex and the guest. A booking is guaranteed by prepayment of at least the first night. Payment is made after the Hotel Complex issues a booking confirmation.
  • 2.9. Prepayment for a guaranteed booking may be made by bank transfer or credit card, as well as by any other cashless or cash method. The payment is deemed made when funds are credited to the Hotel Complex’s bank account not later than three days before arrival. If payment is not received by the deadline, the booking is considered canceled, with additional notice. If the booking is made by a Customer that is a legal entity or sole proprietor, the terms, amount, and timing of the advance payment and other booking conditions may differ from these Rules and are defined by the contract with the Customer.
  • 2.10. The consumer (customer) may cancel the request by notifying the Hotel Complex at least one day before the arrival date by sending a written cancellation by e-mail or fax, or by communicating the cancellation by phone, or by any other means that allow the Hotel Complex to verify that the cancellation originates from the consumer (customer). Any changes and cancellations are made only after the Hotel Complex receives a request from the customer to change or cancel.
  • 2.11. The consumer may unilaterally withdraw from the contract at any time, provided they pay the service provider for actually incurred expenses.
  • 2.12. The Hotel Complex may unilaterally withdraw from the contract in cases provided for by the laws of the Russian Federation.
  • 2.13. In case of late cancellation, late arrival, or no-show, the consumer (Customer) is charged for actual room downtime in the amount of the first night’s price or in accordance with the terms stated on the booking platform through which the booking was made.
  • 2.14. Late cancellation of a guaranteed booking means a cancellation received by the Hotel Complex after 14:00 on the day preceding the scheduled arrival date, or within the time limits specified in the contract with the Customer, as well as on the Internet booking platform selling the Hotel Complex’s services.
  • 2.15. When booking, accommodating, or checking in “from the desk”, the guest chooses the room category, while the right to assign a specific room within that category remains with the service provider.
  • 2.16. For group bookings, the Customer is responsible for compiling the guest list and providing it to the Hotel Complex in due time (no later than 3 days before the expected arrival date).

III. Check-in, Accommodation, and Service Provision

  • 3.1. The Hotel Complex has the right to conclude hotel services contracts with legal entities and individuals.
  • 3.2. A hotel services contract is concluded upon presentation by the consumer of an identity document issued in the prescribed manner, including:
    1. a passport of a citizen of the Russian Federation proving identity within the territory of the Russian Federation;
    2. a passport of a citizen of the USSR proving the identity of a citizen of the Russian Federation until replaced in due time by a passport of a citizen of the Russian Federation;
    3. a birth certificate for a person under 14 years of age. Check-in of minors under 14 years old is based on the identity documents of the parents (adoptive parents, guardians) or accompanying person(s) staying with them, provided the accompanying person(s) present consent from the legal representatives (one of them), as well as the children’s birth certificates. Check-in of minors aged 14 or older without legal representatives nearby is based on the minors’ own identity documents, provided consent from legal representatives (one of them) is presented;
    4. a passport proving the identity of a citizen of the Russian Federation outside the Russian Federation for a person permanently residing outside the Russian Federation;
    5. a temporary identity card of a citizen of the Russian Federation;
    6. a passport of a foreign citizen or another document established by federal law or recognized under an international treaty of the Russian Federation as an identity document of a foreign citizen;
    7. a document issued by a foreign state and recognized under an international treaty of the Russian Federation as an identity document of a stateless person;
    8. a temporary residence permit for a stateless person;
    9. a residence permit for a stateless person.
  • 3.3. When checking in, the consumer signs the registration card and reviews the fire safety memo, the Hotel Complex “GRINN” accommodation rules, and the evacuation plan available in the room.
  • 3.4. Guests are accommodated for the period specified in their requests, but not more than 180 days, and for foreign citizens within the validity period of their visa or migration card.
  • 3.5. Check-out time is 12:00 Moscow time. Check-in time is 14:00 Moscow time. Check-in from 12:00 to 14:00 Moscow time without extra charge is possible only subject to availability of clean, ready rooms of the booked category.
  • 3.6. Subject to availability, at the consumer’s request, one person may be accommodated in a double room with full payment of the room price.
  • 3.7. The total number of guests in the room must correspond to the number of sleeping places in the room.
  • 3.8. An extra bed (folding bed/sofa/sofa-bed) and/or a baby cot is provided upon agreement with the Hotel Complex and is charged according to the current price list approved by the service provider. Extra beds are only available in room categories where the room size and configuration allow it.
  • 3.9. For guaranteed (prepaid) bookings or non-guaranteed bookings where the room has been removed from sale and not available for one day prior to arrival, check-in before check-out time (from 00:00 to 12:00) is charged from the previous day as one night.
  • 3.10. Rates with half-day payment cannot be booked in advance and are applied only for walk-in check-ins after 00:00 of the current day.
  • 3.11. For walk-in check-ins after 00:00 before the 12:00 check-out time and departure after 12:00 before 23:59 within the same calendar date, the charge is one full night.
  • 3.12. In case of late departure, accommodation is charged as follows:
    • no more than 6 hours after check-out time — hourly payment;
    • from 6 to 12 hours after check-out time — half-day payment;
    • from 12 to 24 hours after check-out time — full-day payment.
    Discounts and special offers do not apply to late check-out charges. Late check-out terms may differ depending on the contract between the Hotel Complex and the consumer (customer).
  • 3.13. Visitors of registered guests may enter with mutual consent of the Hotel Complex and the resident guest. Visitors may stay in the room free of charge from 08:00 to 23:00, up to 5 persons, subject to mandatory registration at Reception upon presentation of a passport or another document listed in clause 3.2. If a visitor remains after 23:00, the guest must pay for an extra bed and register the visitor at Reception. If the guest fails to register the visitor, the guest bears full responsibility for all negative consequences (including fines by internal affairs, migration, and tax authorities) related to the lack of registration.
  • 3.14. Extension of stay is processed at Reception subject to availability. The Hotel Complex may move the guest to another room of the same category (if extension in the current room is impossible) or refuse an extension if no rooms are available. Extension requires advance payment for the entire extended period and absence of a confirmed booking for this room in favor of third parties.
  • 3.15. Discounts, promotions, and special offers of the Hotel Complex do not add up. The consumer may choose the most favorable offer applicable to their stay.
  • IV. Payment for Accommodation and Services

    • 4.1. Accommodation is charged based on the check-in time of 14:00 of the current day (Moscow time) and the check-out time of 12:00 of the following day (Moscow time).
    • 4.2. Payment for services is made according to the current price list approved by the Director of the branch of JSC “GRINN Corporation” “GRINN Tourist Multifunctional Complex”.
    • 4.3. Payment for accommodation and services provided by the Hotel Complex may be made in cash or by bank cards in rubles. Customers that are legal entities or sole proprietors may pay cashlessly by bank transfer according to their contracts with the Hotel Complex.
    • 4.4. Accommodation is charged on a prepaid basis for the entire booked period. Credit accommodations are not provided.
    • 4.5. Children under 7 staying in the same room with parents without an extra bed and without meals are accommodated free of charge. If an extra bed is provided for children under 14, a fee is charged according to the current price list. Guests aged 14 and older are accommodated only on main beds.
    • 4.6. The Hotel Complex offers additional services for a fee at the guest’s request, according to the price list for additional paid services (the price list is available in the guest information folder in the rooms).
    • 4.7. Upon departure, the consumer makes the final settlement for hotel and additional paid services and returns the electronic room key to Reception. A fiscal receipt with a printed breakdown is issued.
    • 4.8. The cost of meals and additional services included in the accommodation price but not used by the guest is non-refundable.
    • 4.9. When the initial booking is for single occupancy under a guaranteed booking or through the Hotel’s counterparties, payment for a second or third person is charged as an extra bed according to the current price list approved by the service provider.

    V. Rights and Obligations of Guests

    • 5.1. Priority service at the Hotel Complex is granted to:
      • Heroes of the Russian Federation and the Soviet Union, full Cavaliers of the Order of Glory;
      • disabled persons since childhood, persons with Group 1 disability, and one accompanying person;
      • prosecutors, internal affairs officers, judiciary staff, tax service staff, courier service and communications staff (while performing official duties);
      • servicemen on contract military service sent on official business upon presentation of a travel order (Art. 20 clause 6 of Federal Law of the Russian Federation “On the Status of Servicemen” No. 76-FZ dated 27.05.1998);
      • disabled persons and veterans of the Great Patriotic War;
      • other categories granted priority service under applicable Russian law.
    • 5.2. No other preferential services for the above categories are provided.
    • 5.3. The consumer must:
      • observe the accommodation procedures and payment rules established by the Hotel Complex;
      • verify the accuracy of all information in the registration card and sign it. The guest’s signature confirms the accuracy of the information provided, familiarity with the fire safety memo, the evacuation plan, and agreement with these accommodation rules;
      • keep the premises clean and treat the property and equipment of the Hotel Complex with care;
      • compensate for damage in case of loss of or damage to the Hotel Complex’s property in accordance with Russian law. The amount of damage is determined based on the Hotel Complex price list on the date the damage is discovered. A two-copy report is drawn up in case of damage;
      • within one hour after check-in, report to Reception any detected damage to furnishings, equipment, or finishes. If no such report is made and damage or loss is found upon departure, the Guest must compensate the Hotel Complex for the damage;
      • not disturb other guests, maintain quiet and order in the room and public areas;
      • avoid causing failures of electrical, water, heating, or other technical and engineering systems of the Hotel Complex;
      • in case of an infectious disease or suspicion thereof, immediately vacate the room (Art. 33 of Federal Law No. 52 “On Sanitary and Epidemiological Welfare of the Population” dated 30.03.1999);
      • strictly observe fire safety rules;
      • be responsible for the actions of invited visitors, including liability for damage, violation of the smoking ban, and refusal to pay for services rendered to those persons;
      • pay in due time and in full for additional services not included in the room rate. If payment is overdue, such services are suspended until the debt is fully repaid;
      • when leaving the room, close water taps and windows, switch off lights, TV, and other electrical appliances, and lock the room;
      • on departure not later than the established time, personally contact Reception to return the key and settle all charges for paid services.
    • 5.4. The consumer acknowledges and does not object to the use of video surveillance systems in the Hotel Complex premises (except rooms and toilet cabins) for security purposes.
    • 5.5. If deficiencies in the service are detected, the consumer may demand that they be remedied free of charge. The consumer may terminate the contract if substantial deficiencies are found.
    • 5.6. The following are prohibited in the Hotel Complex:
      • leaving third parties (persons not party to the hotel services contract) in the room or giving them the room key;
      • storing bulky items, flammable materials, weapons, chemical, radioactive, or explosive substances, mercury;
      • persons who have the legal right to carry and store weapons must present documents confirming such right upon request;
      • storing or unauthorized use of pyrotechnics;
      • using personal electric heating devices;
      • smoking or vaping (any tobacco or other products and liquids intended for inhalation of smoke or vapor arising from burning or heating, including electronic cigarettes) anywhere on the property, including rooms and public areas, pursuant to Federal Law No. 15-FZ dated 23.02.2013 “On Protecting Citizens’ Health from the Effects of Environmental Tobacco Smoke and the Consequences of Tobacco Consumption”;
      • moving furniture in the room;
      • disturbing the peace after 23:00;
      • active games, including with balls and other items, warm-ups, training, or dancing in the lobby bar, corridors, halls, floors, elevators, stairwells, and balconies, i.e. areas not intended or equipped for such activities;
      • staying on the premises by persons with an identified infectious disease or suspected of having one;
      • keeping animals, birds, reptiles, insects, etc. in the room without agreement with the Hotel Complex.
      If this clause is violated, the Hotel Complex may unilaterally cease providing services.
    • 5.7. Keeping pets weighing no more than 10 kg in the room is allowed subject to the Hotel Complex’s consent and an additional fee, and compliance with established rules.
    • 5.8. The consumer consents to the processing of personal data by the Hotel Complex in accordance with the approved Personal Data Protection Policy of JSC “GRINN Corporation”, available to the public at: https://grinn-corp.ru/docs/.
    • 5.9. The consumer is advised to immediately inform the Hotel Complex staff of any emergency that may cause damage. If urgent measures are required to prevent greater damage, a report must be immediately submitted to Reception.

    VI. Rights and Obligations of the Hotel Complex

    • 6.1. The Hotel Complex shall post in a visible place, and provide upon request, the following information: these Accommodation Rules; the room price list; information about on-site food and beverage outlets, communications, household services, business center; and information about the superior organization.
    • 6.2. The Hotel Complex shall inform guests at check-in about basic and additional services, the form and procedure of payment, and provide additional paid services in accordance with the approved price list.
    • 6.3. The Hotel Complex may refuse accommodation in the following cases:
      • absence of required documents;
      • documents are invalid or expired;
      • no payment in the prescribed manner or in the required amount;
      • the person is in a state of severe alcohol or drug intoxication without presenting a document confirming otherwise.
      If minors are without parents (adoptive parents, guardians), or if the accompanying person(s) cannot provide the original document authorizing accompaniment of the minor, the Hotel Complex may refuse registration and accommodation to such minor and the unauthorized accompanying person(s), even with a guaranteed booking. If a visitor lacks an identity document as per clause 3.2 or refuses to present it to Reception for entry in the Visitors Log, the visitor may be refused entry to the residential area to prevent potential threats to the life, health, or property of consumers and staff.
    • 6.4. The Hotel Complex reserves the right to refuse accommodation due to rude or inappropriate behavior towards staff or guests, or for gross or systematic (more than twice) violations of the accommodation rules, and may demand payment according to the established procedure.
    • 6.5. The Hotel Complex ensures that each room contains information on accommodation rules, fire safety rules, and instructions for using household electrical appliances.
    • 6.6. The Hotel Complex is responsible for the safekeeping of the consumer’s belongings in accordance with Russian law.
    • 6.7. The Hotel Complex is not liable for loss of money, other currency valuables, securities, credit and phone cards, jewelry, or other valuables not deposited for safekeeping.
    • 6.8. If lost items are found, the Hotel Complex informs the owner. The Hotel Complex stores a guest’s forgotten item for 6 months. Valuables and large sums of money are stored for up to 1 year from the date of the Lost-and-Found Report. Opened food items are not stored and are disposed of. If packaging is intact, food is placed in storage for 3 days. Sealed personal cosmetics are stored for 3 days; opened cosmetics are not stored and are disposed of. At the guest’s instruction, the Hotel Complex may ship forgotten items to the address specified by the guest. Return is carried out as agreed with the Hotel Complex. Shipping costs are borne by the guest.
    • 6.9. The Hotel Complex is not responsible for the guest’s health in case of consumption of food or beverages purchased outside the Hotel Complex.
    • 6.10. The Hotel Complex reserves the right to enter the room without prior consent in case of smoke, fire, flooding, or if the consumer violates these rules, public order, or appliance usage rules.
    • 6.11. The Hotel Complex ensures full compliance of provided services with SES standards and other regulatory acts.
    • 6.12. The Hotel Complex ensures confidentiality of information about visitors.
    • 6.13. The Hotel Complex undertakes to respond promptly to the consumer’s requests to eliminate inconveniences or malfunctions in the room stock.
    • 6.14. In case of violation of the smoking ban, the Hotel Complex may contact law enforcement to hold the guest or their visitors administratively liable. If the Hotel Complex is held administratively liable due to the resident guest’s (and/or their visitors’) violation of the smoking ban, the Hotel Complex reserves the right to claim from the violator compensation equal to the fine imposed on the hotel by competent state authorities. Smoking in the room entails compensation for special additional cleaning (extended airing, deodorizing agents, dry cleaning and washing of curtains, tulle, textiles) in the amount of 5,000 rubles. The fact of smoking is confirmed by an internal report drawn up by Hotel Complex staff. If the guest refuses to sign or participate, a corresponding note is made.
    • 6.15. The Hotel Complex may change the guest’s room and require immediate vacation of the previously occupied room if urgent repair, sanitary-epidemiological, or other measures are required to eliminate causes that threaten or impede normal (safe and quality) use.
    • 6.16. If the guest is absent on the departure day for more than 6 hours after the check-out time, hotel management may form a commission and inventory the property in the room. Valuables such as money, precious metals, important documents, and other items are accepted for safekeeping. Other property is placed in the Hotel Complex storage.
    • 6.17. The Hotel Complex may refuse a late check-out if it was not confirmed at the time of booking and no rooms are currently available.

    VII. Dispute Resolution Procedure

    • 7.1. The Book of Feedback and Suggestions is kept at Reception and is issued upon the guest’s request. Requests and complaints are reviewed no later than 10 calendar days from the date of submission.
    • 7.2. In the event of disputes regarding service quality, both parties should seek resolution on site. If the issue cannot be resolved on site, the consumer must submit claims in writing. Failure to do so may serve as grounds for full or partial refusal to satisfy the claim.
    • 7.3. If it is impossible to eliminate identified deficiencies on site, a report is drawn up in two copies and signed by the consumer and an authorized representative of the Hotel Complex, indicating all comments.
    • 7.4. If the Hotel Complex administration failed to eliminate identified deficiencies on site, the consumer, having a report on the identified violations, has the right to submit claims within 14 days from the date of their discovery.

    GENERAL PROVISIONS

    1.1. This Policy has been developed and is applied in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of July 27, 2006 “On Personal Data”, Federal Law No. 38-FZ of March 13, 2006 “On Advertising”, Federal Law No. 149-FZ of July 27, 2006 “On Information, Information Technologies and Protection of Information”, and other regulatory acts in the field of personal data protection applicable within the territory of the Russian Federation.

    1.2. This Policy defines the procedure for the collection, accounting, processing, accumulation, use, distribution, and storage of personal data of individuals, including clients, counterparties and/or their representatives, and users of the websites operated by JSC “GRINN Corporation” (registered address: 4 Kromskoye Highway, Orel, Oryol Region, 302042, Russia; Tax ID 4629045050) (hereinafter — the “Operator”), as well as other individuals who are not employees of the Operator and have voluntarily provided their personal data.

    1.3. The purpose of this Policy is to protect the personal data of the aforementioned individuals from unauthorized access and disclosure.

    1.4. Definitions:

    • Personal Data — any information relating to a directly or indirectly identified or identifiable individual (data subject), including but not limited to name, surname, patronymic, date and place of birth, address, marital and social status, education, profession, income, and other identifying data.

    • Processing — any operation or set of operations performed on personal data, including collection, systematization, accumulation, storage, updating, use, dissemination, anonymization, blocking, or destruction.

    • Dissemination — actions aimed at transferring personal data to a certain group of persons or making them available to the general public.

    • Use — operations with personal data carried out by the Operator to make decisions or take actions affecting the rights and interests of the data subject or third parties.

    • Blocking — temporary suspension of personal data processing.

    • Destruction — actions resulting in the irreversible loss of personal data.

    • Confidentiality — mandatory non-disclosure of personal data without the data subject’s consent or other legal basis.

    • Information — any data regardless of format.

    • Documented Information — recorded information with identifying attributes.

    • Personal Data Information System — a system comprising databases and technologies used for automated or non-automated processing of personal data.

    1.5. When processing personal data, the Operator adheres to the following principles:

    • Lawfulness and fairness;

    • Purpose limitation;

    • Data minimization and relevance;

    • Accuracy and adequacy;

    • Storage limitation;

    • Integrity and confidentiality.

    1.6. This Policy governs the Operator’s handling of personal data with and without the use of automation, ensuring data confidentiality and implementing preventive legal compliance measures.

    1.7. The Operator processes personal data legally and fairly to fulfill legal obligations, safeguard legitimate interests, and ensure the rights of data subjects.

    1.8. This Policy applies to data obtained from:

    • Individuals under civil law relations with the Operator;

    • Representatives of legal entities and sole proprietors in contractual relations;

    • Users of the Operator’s websites (grinn-corp.ru, linia-market.ru and subdomains);

    • Other individuals whose data the Operator may lawfully process.

    Personal data of employees are regulated by a separate internal policy dated 24.09.2021, Order No. 276.

    1.9. The Operator processes the following categories of personal data:

    • Name, surname, patronymic;

    • Birth date and place;

    • Citizenship;

    • Contact details (phone, email);

    • Identity document data;

    • Residential and registration address;

    • Taxpayer identification number;

    • Pension insurance number;

    • Order and communication history.

    1.10. The Operator may also process non-personally identifiable technical data collected automatically, including:

    • Browser type;

    • IP address;

    • Cookie data;

    • Referrer URL;

    • Access times.

    1.11. The Operator does not process special categories of personal data such as racial origin, religious beliefs, political opinions, or biometric data.

    1.12. Access by third parties is restricted except as required by law. Unspecified data is destroyed immediately upon receipt.

    1.13. Personal data is processed for the purposes of:

    • Contract execution;

    • Order handling and customer service improvement;

    • Marketing and promotional campaigns (with consent);

    • Website analytics and security.

    1.14. Processing activities include:

    • Collection, recording, storage, use, transfer, anonymization, deletion, etc.

    1.15. Cross-border data transfer is permitted with the subject’s consent and appropriate safeguards.

    COLLECTION, USE, AND DISCLOSURE

    2.1. Processing begins upon obtaining the subject’s consent, given in written, verbal, or conclusive form, including:

    • Partner card registration;

    • User account creation on grinn-corp.ru or linia-market.ru;

    • Phone communication with the call center;

    • Participation in online promotions.

    2.2. Consent is not required where processing is mandated by law or for contract fulfillment.

    2.3. Personal data may be submitted:

    • In writing in offices;

    • Online via websites;

    • Verbally via call center;

    • Other lawful means.

    2.4. Consent is presumed upon completion of any of the above actions and remains valid until revoked in writing.

    2.5. Consent may be withdrawn at any time by sending written notice to the Operator’s address. Upon withdrawal, processing ceases within 30 days unless otherwise stipulated by law or contract.

    2.6. Data transfer to third parties requires written or digital consent, signed with a digital signature if electronic.

    2.7. The Operator may share data with government bodies without consent if required by law.

    2.8–2.11. Data subjects may explicitly limit dissemination of their data; consent for dissemination must be provided separately and may be revoked at any time.

    PROCESSING AND SECURITY MEASURES

    3.1. Only authorized personnel may process personal data. They are required to maintain confidentiality.

    3.2. Third-party processing is allowed under strict confidentiality and security obligations.

    3.3. Data is processed both manually and electronically. Legal consequences are not based solely on automated processing.

    3.4. Confidentiality is preserved unless the subject voluntarily shares their data publicly.

    DATA SECURITY REQUIREMENTS

    4.1–4.8. The Operator implements legal, organizational, and technical safeguards including:

    • Threat identification;

    • Access control;

    • Data encryption and storage protocols;

    • Monitoring and incident response;

    • Limiting processing environments;

    • Virus protection and intrusion prevention;

    • Confidential storage practices;

    • No disclosure of security protocols.

    CONSENT TO MARKETING COMMUNICATIONS

    5.1. By opting in for marketing (via form, website checkbox, or call center), the subject consents to receiving advertising via phone and email.

    5.2. The subject affirms that the provided data is accurate and submitted voluntarily.

    DATA RETENTION

    6.1. Personal data is securely stored in both electronic databases (protected by passwords) and physical archives (locked cabinets).

    FINAL PROVISIONS

    7.1. Employees violating data policies are subject to disciplinary action under Russian law.

    7.2. This Policy is an internal document of the Operator and takes effect upon approval.

    7.3–7.5. The Operator’s additional responsibilities are defined by applicable data protection legislation. Updates to this Policy are made by order of the Director and published online.