1. General Provisions

This personal data processing policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by LLC “Jet Project” (hereinafter referred to as the Operator).

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy, to be its most important goal and condition for carrying out its activities.
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 may obtain about visitors to the website https://jetownersclub.com/.

2. Basic Terms 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 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 ensuring their availability on the Internet at the network address https://jetownersclub.com/.
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 resulting in the impossibility of determining, without the use of additional information, the принадлежность of personal data to a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed using automation tools or without the use of such 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 independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://jetownersclub.com/.
2.9. Personal data permitted by the personal data subject for dissemination — 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 dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User — any visitor to the website https://jetownersclub.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. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at familiarizing an unlimited group of persons with personal data, including publication of personal data in mass media, placement in information and telecommunication networks, or provision of 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 individual or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or destruction of physical carriers 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;
— in the event of withdrawal by the personal data subject of consent to the processing of personal data, as well as submission of a request to terminate 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 fulfillment of obligations предусмотренных 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, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— report to the authorized body for the protection of the rights of personal data subjects, upon request of this body, the necessary information within 10 days from the date of receipt of such 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 unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions regarding personal data;
— terminate the transfer (dissemination, 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. 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 in cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, except in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand from the operator clarification of their personal data, blocking or destruction thereof if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
— put forward a condition of prior consent when processing personal data for the purposes of promoting goods, works and services on the market;
— withdraw consent to the processing of personal data, as well as send a demand to terminate the processing of personal data;
— appeal unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable information about themselves;
— inform the Operator about clarification (updating, modification) of their personal data.
4.3. Persons who provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent shall bear liability in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Processing of personal data is carried out on a lawful and fair basis.
5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data processed 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. Excessive processing of personal data in relation to the stated purposes of their processing is not allowed.
5.6. When processing personal data, accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form allowing identification of the personal data subject no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized upon achievement of processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

Purpose of personal data processing: informing the User by sending emails.
Personal data:

• surname, first name, patronymic;
• email address;
• phone numbers.
• Legal grounds:
• contracts 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 emails to the email address.

7. Conditions for Processing Personal Data

7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. Processing of personal data is necessary for achieving purposes provided for by an international treaty of the Russian Federation or by law, for the implementation of functions, powers and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Processing of personal data is necessary for exercising the rights and legitimate interests of the operator or third parties or for achieving socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Processing of personal data is carried out, access to which is granted by the personal data subject to an unlimited number of persons or at their request (hereinafter referred to as publicly available personal data).
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary for full compliance with the requirements of current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures excluding access to personal data by unauthorized persons.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer data to a third party for fulfillment of obligations under a civil law contract.
8.3. In case of identifying inaccuracies in personal data, the User may update them independently by sending a notification to the Operator at the Operator’s email address sales@jetownersclub.com marked “Updating personal data”.
8.4. The period of personal data processing is determined by achievement of the purposes for which the personal data were collected, unless another period is provided by contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator’s email address sales@jetownersclub.com marked “Withdrawal of consent to the processing of personal data”.
8.5. All information collected by third-party services, including payment systems, communication means 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 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. Restrictions established by the personal data subject on transfer (except granting access), as well as on processing or conditions of processing (except obtaining access) of personal data permitted for dissemination, 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 confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form allowing identification of the personal data subject no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, contract to which the personal data subject is a party, beneficiary or guarantor.
8.9. A condition for termination of personal data processing may be achievement of the purposes of personal data processing, expiration of the consent period of the personal data subject, withdrawal of consent by the personal data subject or demand to terminate processing of personal data, as well as identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Received Personal Data

9.1. The Operator carries out collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with receipt and/or transfer of received information via information and telecommunication networks or without such transfer.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities on 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 cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Before submitting the above notification, the Operator is obliged to obtain from foreign state authorities, foreign individuals, foreign legal entities to whom cross-border transfer of personal data is planned, relevant information.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the personal data subject, 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 their personal data by contacting the Operator via email at sales@jetownersclub.com.
12.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The Policy remains in force indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://jetownersclub.com/policy_eng