Casa Del Mare

Policy on the Processing of Personal Data
1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of the Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Wellton Property LLC (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 human and civil rights and freedoms in the processing of their personal data, including the protection of rights to privacy, personal and family secrets.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about visitors to the website https://casadelmare.online.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary termination 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 information materials, as well as programs for electronic computers and databases, ensuring their availability on the internet at the network address https://casadelmare.online.
2.4. Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions as a result of which it is impossible to determine, without using 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 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 or physical person, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, 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://casadelmare.online.
2.9. Personal data allowed by the subject of personal data for distribution – personal data to which an unlimited number of persons have access, provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data allowed for distribution).
2.10. User – any visitor to the website https://casadelmare.online.
2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing with personal data an unlimited circle of persons, including public disclosure of personal data in the media, placement in 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 state authority, a foreign physical or foreign legal person.
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 material carriers of personal data.
3. Main 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 subject of personal data;
• continue processing personal data without the consent of the subject of personal data 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 provided by the Personal Data Law and the adopted regulations unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the subject of personal data, at their request, with information regarding the processing of their 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;
• inform the authorized body for the protection of the rights of personal data subjects, at their request, of the necessary information within 10 days from the date of receipt of such a request;
• publish or otherwise provide unrestricted 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, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions with respect to personal data;
• stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
• fulfill other obligations provided for by the Personal Data Law.

4. Main 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 in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data relating to other personal data subjects unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• require the operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take measures provided 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;
• withdraw consent to the processing of personal data, as well as to send a demand to stop processing personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or to the court against unlawful actions or inaction of the Operator in the processing of their personal data;
• exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with reliable data about themselves;
• inform the Operator about the clarification (updating, changing) of their personal data.

4.3. Persons who provided the Operator with unreliable information about themselves, or information about another subject of personal data without the consent of the latter, bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data is carried out on a legal and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. The processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. The merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. The redundancy of processed personal data concerning the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of processing personal data are ensured. The operator takes the necessary measures and (or) ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. The storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor. The processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in case of loss of necessity to achieve these purposes unless otherwise provided by federal law.
6. Purposes of Personal Data Processing

• The purpose of processing is to provide the User with access to services, information, and (or) materials contained on the website.
• Personal data:
• surname, first name, patronymic
• phone numbers
• Legal grounds:
• agreements concluded between the operator and the subject of personal data
• Types of personal data processing:
• Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data

7. Conditions for Personal Data Processing
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary for achieving the goals provided for by an international treaty of the Russian Federation or the law, for the exercise of the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
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 an 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 execution of an agreement to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of 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 for the exercise of the rights and legitimate interests of the operator or third parties, or for achieving socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. The processing of personal data is carried out if the personal data were made publicly available by the subject of personal data or at their request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collecting, Storing, Transferring, and Other Types of Personal Data Processing
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 current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to exclude unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law agreement.
8.3. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address a.nepomniashiy.uk@gmail.com with the note "Updating personal data."
8.4. The processing period for personal data is determined by achieving the purposes for which the personal data were collected unless a different period is provided for by the agreement or current legislation. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator's email address a.nepomniashiy.uk@gmail.com with the note "Withdrawal 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. The 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 paragraph.
8.6. Established by the subject of personal data prohibitions on transfer (except for granting access), as well as processing or conditions for processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined 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 determining the subject of personal data, no longer than required by the purposes of processing personal data unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data, or a demand to stop processing personal data, as well as the detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with 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 performs automated processing of personal data with the receipt and/or transmission of the received information through information and telecommunication networks or without it.
10. Cross-Border Transfer of Personal Data
10.1. Before starting 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 their 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 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 access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data unless otherwise provided by federal law.
12. Final Provisions
12.1. The User can obtain any clarifications on matters of interest regarding the processing of their personal data by contacting the Operator via email at a.nepomniashiy.uk@gmail.com.
12.2. This document will reflect any changes to the personal data processing policy by the Operator. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://casadelmare.online/privacy/.