This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “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 the Company. 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 the Limited Liability Company Nehama Sanatorium, OGRN 1111690013049, TIN 1660150678, represented by Director Guzel Zabikhulovna Abuzyarova (hereinafter referred to as the Operator).
1.1. The Operator’s most important goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including protecting their rights to privacy and personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://mednehama.ru/.
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://mednehama.ru/.
2.4. Personal data information system – a collection of personal data contained in databases and the information technology and technical means that ensure their processing.
2.5. Depersonalization of personal data – actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity, or individual who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable user of the website https://mednehama.ru/.
2.9. Personal data authorised by the subject of personal data for distribution – personal data to which an unlimited circle of persons is granted access by the subject of personal data by giving consent to the processing of personal data authorised by the subject of personal data for distribution in accordance with the procedure provided for by the Personal Data Act (hereinafter – personal data authorised for distribution).
2.10. User – any visitor to the website https://mednehama.ru/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including the publication of personal data in the media, placement on information and telecommunications 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 state authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data means any actions that result in the irretrievable destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.
3.1. The Operator has the right to:
3.2. The operator is obliged to:
4.1. Personal data subjects have the right to:
4.2. Personal data subjects are obliged to:
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.
5.1. Booking form
5.2. Callback request form
5.3. Message/question form
5.4. The website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (Yandex Metrica).
5.5. The above data is referred to throughout this Policy as Personal Data.
5.6. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, or intimate life.
5.7. The processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions provided for in Article 10.1 of the Personal Data Law are observed.
5.8. The User’s consent to the processing of personal data permitted for distribution shall be formalized separately from other consents to the processing of his or her personal data. In doing so, the conditions provided for, in particular, in Article 10.1 of the Personal Data Act shall be observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8.1 The User provides the Operator with consent to the processing of personal data permitted for distribution directly.
5.8.2 The Operator is obliged, within three working days of receiving the specified consent from the User, to publish information about the conditions of processing, the existence of prohibitions and conditions for the processing of personal data permitted for distribution by an unlimited circle of persons.
5.8.3 The transfer (distribution, provision, access) of personal data permitted for distribution by the subject of personal data must be terminated at any time at the request of the subject of personal data. This request must include the surname, first name, patronymic (if any), contact information (telephone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it is addressed.
5.8.4 Consent to the processing of personal data permitted for distribution shall cease to be valid from the moment the Operator receives the request specified in clause
5.8.3 of this Policy regarding the processing of personal data.
5.9. In order to obtain anonymized statistical information about website traffic and usage, the Operator may additionally use a web analytics system that operates without the use of cookies and without generating persistent user identifiers. This system processes anonymized statistical data (pages viewed, date and time of visit, device type, browser, interface language, country/city in aggregate form, marketing campaign parameters without personal identifiers). Visitors’ personal identifiers are not generated, IP addresses are anonymized, and the information obtained is used only in aggregate form for statistics and to improve the website’s performance.
6.1. Personal data shall be processed on a lawful and fair basis.
6.2. Personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Personal data processing that is incompatible with the purposes of personal data collection shall not be permitted.
6.3. It is not permitted to combine databases containing personal data that are processed for purposes that are incompatible with each other.
6.4. Only personal data that meets the purposes of its processing shall be processed.
6.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes of its processing is not permitted.
6.6. When processing personal data, the accuracy, adequacy, and, where necessary, relevance of personal data in relation to the purposes of processing personal data shall be ensured. The operator shall take the necessary measures and/or ensure that measures are taken to delete or clarify incomplete or inaccurate data.
6.7. Personal data shall be stored in a form that allows the identification of the data subject for no longer than is necessary for the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor. The processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
7.1. Purpose of processing the User’s personal data:
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending a letter to the Operator at info@mednehama.ru with the subject line “Opt out of notifications about new products and services and special offers.”
7.3. Anonymized User data collected using Internet statistics services is used to collect information about User actions on the website and to improve the quality of the website and its content.
8.1. The legal grounds for the Operator’s processing of personal data are:
8.2. The Operator processes the User’s personal data only if it is filled in and/or sent by the User independently through special forms located on the website https://mednehama.ru/ or sent to the Operator by e-mail. By filling out the appropriate forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is permitted in the User’s browser settings (cookies are enabled and JavaScript technology is used).
8.4. The subject of personal data independently decides on the provision of their personal data and gives their consent freely, of their own will and in their own interest.
9.1. Personal data is processed with the consent of the data subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the objectives set out in an international treaty of the Russian Federation or by law, to perform the functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
9.3. 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.
9.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party or beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the data subject or a contract under which the data subject will be the beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
9.6. Personal data is processed, access to which is provided to an unlimited number of persons by the personal data subject or at his request (hereinafter referred to as publicly available personal data).
9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
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 current legislation in the field of personal data protection.
10.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of applicable law or if the subject of the personal data has given consent to the Operator to transfer the data to a third party in order to fulfill obligations under a civil law contract.
10.3. If inaccuracies are found in personal data, the User may update them independently by sending a notification to the Operator at the Operator’s email address info@mednehama.ru with the subject line “Update of personal data.”
10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by the contract or applicable law.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator by email to the Operator’s email address info@mednehama.ru marked “Withdrawal of consent to the processing of personal data”.
10.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obliged to familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. Prohibitions established by the subject of personal data 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, do not apply in cases of processing personal data in the state, public, and other public interests defined by the legislation of the Russian Federation.
10.7. When processing personal data, the operator shall ensure the confidentiality of personal data.
10.8. The operator shall store personal data in a form that allows the identification of the personal data subject for no longer than is necessary for the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
10.9. The conditions for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the detection of unlawful personal data processing.
11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
11.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunications networks or without them.
12.1. Before starting the cross-border transfer of personal data, the Operator must make sure that the foreign country to which the personal data is supposed to be transferred provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only be carried out with the written consent of the personal data subject to the cross-border transfer of their personal data and/or the performance of a contract to which the personal data subject is a party.
The operator and other persons who have access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.
14.1. The user may obtain any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator by email at info@mednehama.ru.
14.2. This document will reflect any changes in the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at: https://mednehama.ru/en/privacy-policy/.
Short legal name: Nehama Sanatorium LLC
Full legal name: Limited Liability Company Nehama Sanatorium “NEKAMA” Nehama Sanatorium “NEKAMA”
Legal address: 420053, Kazan, Poperechno-Noksinskaya St., 46
Actual address: 420070, Republic of Tatarstan (Tatarstan), Laishevsky District, Matyushinskoe Village, Nechama Territory, Building 1 (Kazan, Petrovsky Settlement)
TIN 1660150678
KPP 166001001
OGRN 1111690013049, Series 16 No. 007006076, March 4, 2011, at the Interdistrict Inspectorate of the Federal Tax Service No. 6 for the Republic of Tatarstan 1686
Settlement account No. 40702810000000004161
Bank JSC “TATSOZBANK” Kazan
BIC 049205703
Correspondent account No. 30101810500000000703
Phone: 8 (843) 223-06-39, 8 (843) 590-72-26
Email address: info@mednehama.ru
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