The Privacy Policy (hereinafter - the Policy) applies to the information that Limited Liability Company "CST" and/or its affiliates, including all persons belonging to the same group with ZALA AERO GROUP (hereinafter - ZALA GROUP), can obtain about the User during the User's use of the Website (https://zala.aero), services, services, programmes, products or services of ZALA GROUP (hereinafter - the Services) and in the course of execution by ZALA GROUP of any agreements and contracts with the User.
The User's consent to the Policy, expressed by him within the framework of his relationship with one of the listed persons, extends to all other listed persons.
This Policy explains how ZALA GROUP processes and protects Users' personal data.
ZALA GROUP has the right to publish additional or amended provisions of the Policy. For specific Services, ZALA GROUP is also entitled to publish additional provisions supplementing and/or amending this Policy.
Using the Services and providing ZALA GROUP with information necessary to initiate further interaction, in accordance with part 3 of Art. 6 of the Federal Law dated 27.07.2006 № 152-FZ "On Protection of Personal Data", part 1 of Art. 18 of the Federal law from 13.03.2006 № 38-FZ "About advertising", the User:
- expresses consent to the processing of personal data with or without the use of automation, including collection, recording, systematisation, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion, destruction of personal data and other use of provided and/or received information in accordance with this Policy;
- confirms the provision of ZALA GROUP consent to the possible transfer of their personal data to third parties, including for the purposes of providing advertising messages.
- Personal data of users, which ZALA GROUP receives and processes
1.1 For the purposes of this Policy, "user's personal data/personal information" shall mean:
1.1.1 Personal data (surname, first name and patronymic, e-mail address, postal address, contact phone number and any information relating directly or indirectly to a certain individual), which the User provides about himself/herself, including when registering (creating an account) on the Website or in the process of using the Services. The information mandatory for provision (rendering) of the Services is explicitly labelled. Other information is provided by the user at his/her discretion.
1.1.2. anonymised data automatically received by ZALA GROUP while the user is on any page of the Website, with the help of software installed on the user's device: IP-address, information from cookies, information on the
the user's browser (or other programme with the help of which the Site services are accessed), access time, address of the requested page and other similar information.
1.2 ZALA GROUP does not verify the reliability of personal data provided by the User and has no possibility to assess his/her capacity. However, ZALA GROUP assumes that the User provides reliable and sufficient personal information and keeps this information up to date. ZALA GROUP does not control and is not responsible for the websites of third parties, to which the user can go via links available on the websites of ZALA GROUP. Third party sites may have their own privacy policies and may collect or request other personal data from the user.
- Purposes of processing users' personal data
2.1 ZALA GROUP processes only those personal data that are necessary for the provision and improvement of services.
2.2 ZALA GROUP may use the user's personal data for the following purposes:
2.2.1 Identification of the party within the framework of the Service provision.
2.2.2 Providing the User with timely and personalised Services and offers (including advertising).
2.2.3 Improving the quality of the Services and developing new ones.
2.2.4 Feedback from the User to provide information at the User's request.
2.2.5. Carrying out statistical and other research on the basis of anonymised data.
2.2.6 Implementation and/or fulfilment of functions, powers and duties assigned by the legislation of the Russian Federation to ZALA GROUP. - Transfer of user's personal data to third parties
3.1 The User's personal data shall be kept confidential, except in cases of processing personal data to which the User has granted access to an unlimited number of persons or at the User's request.
3.2 ZALA GROUP has the right to transfer personal data of the User to third parties in the following cases:
3.2.1. the User has given his/her consent to such actions.
3.2.2 The transfer is necessary to achieve the objectives, implementation and fulfilment of functions, powers and duties assigned to ZALA GROUP by this policy and the legislation of the Russian Federation.
3.3.3 The transfer is provided for by Russian or other applicable law under the procedure established by law. - Measures applied for the protection of users' personal data
ZALA GROUP takes necessary and sufficient organisational and technical measures for protection of personal data of the user from illegal or accidental access, destruction, change, blocking, copying, distribution, and also from other illegal actions with personal data of the third parties. Personal data is stored until the moment of termination of ZALA GROUP activity or until the moment of achievement of Objectives
processing of personal data of users. The maximum period of storage of personal data is 75 years from the date of its receipt from the User.
- Rights and obligations of the User
5.1 ZALA GROUP takes reasonable and possible measures to maintain the accuracy and relevance of the personal data available to ZALA GROUP, as well as the removal of outdated and other inaccurate or unnecessary personal data, however, the User is responsible for providing accurate information, as well as for updating the provided data in case of any changes.
5.2 The User can at any time change (update, supplement) the personal information provided by him or its part, as well as parameters of its confidentiality by contacting ZALA GROUP.
5.2.1 The User has the right to withdraw consent to the processing of personal data by ZALA GROUP at any time by sending a written notice marked "withdrawal of consent to the processing of personal data" to the address: 426063 RF, Udmurt Republic, Izhevsk, Vorovskogo str.Vorovskogo, 130, LLC "CST", in this case the withdrawal of the User's consent to the processing of personal data entails the deletion of the user's account from the Site, as well as the destruction of records containing personal data in the systems of processing personal data of ZALA GROUP, which may make it impossible to use the Services of ZALA GROUP.
5.3 The user has the right to receive information concerning processing of his personal data in ZALA GROUP for what purpose he has the right to send the written enquiry with marking "enquiry of the information on an order of processing of the personal data" to the address: 426063 RF, Udmurt Republic, Izhevsk, Vorovskogo street, 130, LLC "CST".
5.4 To fulfil the provisions in clauses 5.2 and 5.3 of this Policy, ZALA GROUP may require confirmation of the User's identity by requesting such confirmation in any form not contrary to the law. - Feedback. Questions and suggestions
The User may send all suggestions or questions regarding this Policy to the address: 130 Vorovskogo St., Izhevsk, Izhevsk, 426063 RF, Udmurt Republic, CST Ltd.
