Personal Data Processing Policy

Thank you for visiting website and for taking the time to read this confidentiality policy. The Russian Travel Market Signals Platform respects the privacy of all users of its website. Website users include corporations, companies, firms and private individuals.

This Confidentiality Policy explains how the Russian Travel Market Signals Platform handles information collected as part of users' activities on the Website.

Website users are deemed to have read, accepted and recognized the validity of this Confidentiality Policy. Should a Website user not accept the terms of this Confidentiality Policy, he or she should stop using the Website. Even in those circumstances, the user remains obligated to submit Company Reports in accordance with applicable laws and regulations. The Russian Travel Market Signals Platform may change this Confidentiality Policy at any time and without notice. Website users are asked to regularly review the Confidentiality Policy to check whether changes have been made. If they continue to use the Website after changes have been published, users are deemed to have accepted said changes to the Confidentiality Policy.

1. COLLECTION OF PERSONAL INFORMATION

In the course of operating the Website, the Russian Travel Market Signals Platform may collect personal information about its users.

"Personal information" is defined as information permitting the identification of private individuals, including their name, contact information, e-mail address, etc. Russian Travel Market Signals Platform will collect users' personal information when they provide it at the time of registration for the Russian Travel Market Signals Platform service, particularly when subscribing to a newsletter, downloading the information or placing a request via the Website. Russian Travel Market Signals Platform may also receive their personal information through its commercial partners or other third parties, provided those third parties confirm that the user authorized the disclosure of personal information.

2. USE OF PERSONAL AND/OR CONFIDENTIAL INFORMATION

The Russian Travel Market Signals Platform takes seriously its responsibility to properly handle personal and/or confidential information provided by everyone it deals with. The Russian Travel Market Signals Platform limits the personal and confidential information collected to that necessary for conducting business.

Only the Russian Travel Market Signals Platform personnel authorized to follow up on requests for information, verification and analyses have access to personal and/or confidential information. The Russian Travel Market Signals Platform informs such employees about their obligation to maintain confidentiality.

The Russian Travel Market Signals Platform may use personal and confidential information for the following purposes:

a) To provide the services or information requested by the user, contact him or her in reply to a question, ensure quality assurance internally or manage the quality of the information provided via the Website.

b) To provide the user with the latest information and updates and offer materials and training related to our activities. Such electronic messages are, however, sent out in accordance with anti-spam legislation, and the user may ask the Russian Travel Market Signals Platform to remove his or her e-mail address from its distribution list at any time.

c) The Russian Travel Market Signals Platform may also use personal and confidential information if it reasonably believes that such information may be relevant to an investigation into a violation of federal, provincial or foreign law, or to ensure the protection or defense of lawful interests.

d) The Russian Travel Market Signals Platform may use confidential information in accordance with the Russian Travel Market Signals Platform Schedules of Contributions and the Conditions of Use of the Russian Travel Market Signals Platform and Reporting System, particularly to ensure the user's compliance with those terms.

the Russian Travel Market Signals Platform keeps the personal and/or confidential information it collects for as long as deemed necessary to carry out its activities.

3. COMMUNICATION OF PERSONAL AND/OR CONFIDENTIAL INFORMATION

The Russian Travel Market Signals Platform pledges not to publicly disclose, sell, rent or share personal and/or confidential information to any third party, including its members.

The Russian Travel Market Signals Platform will only disclose personal and/or confidential information to third parties in the following circumstances:

a) The user has specifically authorized the Russian Travel Market Signals Platform to disclose personal information for a given purpose.

b) The third party involved is acting on the Russian Travel Market Signals Platform behalf as its agent or supplier of goods or services, and the information is provided to them for the sole purpose of facilitating the delivery of the Russian Travel Market Signals Platform services. These third parties must respect strict contractual conditions that require them to maintain the confidentiality of all information and to use such information for the sole purpose of delivering the Russian Travel Market Signals Platform services.

c) Disclosure is required to meet the requirements and facilitate the delivery of a specific Russian Travel Market Signals Platform service in accordance with applicable conditions, particularly legal obligations.

d) A lawful ruling rendered by a court, institution or relevant authority compels the Russian Travel Market Signals Platform to provide personal information, summons the Russian Travel Market Signals Platform to produce documents, or otherwise requires the Russian Travel Market Signals Platform to disclose the information. the Russian Travel Market Signals Platform also reserves the right to report to authorities any activity the Russian Travel Market Signals Platform believes, in good faith, to be illegal. the Russian Travel Market Signals Platform may disclose certain personal and/or confidential information when it believes that disclosure is necessary to protect its own rights, property and security as well as that of third parties, or to ensure the fulfillment of the user's obligations towards the Russian Travel Market Signals Platform.

4. SECURITY OF PERSONAL AND CONFIDENTIAL INFORMATION

The security and protection of personal and/or confidential information are important to the Russian Travel Market Signals Platform. the Russian Travel Market Signals Platform implements reasonable technical, contractual, administrative and material measures to protect the personal and confidential information users provide, including secure 128 bit encryption (Secure Socket Layer – SSL) when required. Although 100% protection cannot be guaranteed, the Russian Travel Market Signals Platform has implemented rigorous methods that meet strict security standards to ensure personal and confidential information is protected.

The Russian Travel Market Signals Platform employees who have access to this information may only use it for the purposes indicated in the Confidentiality Policy herein and according to applicable laws and regulations.

The Russian Travel Market Signals Platform employees are not authorized to discuss information concerning a user unless the correct answer to the contact's security question recorded for the user is provided. The Russian Travel Market Signals Platform reserves the right, however, to directly contact a user concerning contributions due to the Russian Travel Market Signals Platform by virtue of applicable laws and regulations and to discuss related topics.

5. ACCESS TO PERSONAL INFORMATION AND CHANGES

Users may access their personal information to view, update or change it by contacting of RMAA Group LLC: hello@travel-analytics.ru, or by written notification to the address of RMAA Group LLC, Moscow region, Krasnogorsk district, Saburovo village, Zvezdnaya street, 9-7, 143443.

6. UNDER-AGE USERS

The Russian Travel Market Signals Platform takes appropriate precautions to comply with applicable laws concerning the privacy of under-age persons. The content of the Website is designed for a general audience and not for under-age users. The Russian Travel Market Signals Platform therefore does not seek to collect personal information from under-age persons without previously checking that consent has been given by parents or other authorized persons in accordance with the law. Should the user believe otherwise, he or she should contact The Russian Travel Market Signals Platform to discuss the issue.

7. COLLECTION OF NON-PERSONAL INFORMATION

In the course of operating the Website, The Russian Travel Market Signals Platform may collect non-personal information about its users.

"Non-personal information" is defined as the name of the Internet domain (e.g. "xyzcompany.com") and the Internet protocol address (IP address) used to access the Website, the date and time of the visit, the pages visited, the browser type and version or the operating system used, as well as the previous and subsequent website accessed. General information, such as demographic statistics on users, the number of visitors and the average usage time of the Website are also considered non-personal information.

The Russian Travel Market Signals Platform collects or gathers non-personal information in the course of its Website operations. For example, when the user chooses to visit the Website, web servers may automatically collect non-personal information provided via the user's browser or stored as "cookies" or other digital markers.

8. USE OF NON-PERSONAL INFORMATION

The Russian Travel Market Signals Platform uses non-personal information to follow up on Website use and to improve its management, conduct statistical analyses on all user characteristics and behaviour, measure demographic variables and user interest in particular services, describe its services to third parties and potential business partners, and determine how The Russian Travel Market Signals Platform resources should be applied and/or could be made more efficient. No personal information is disclosed during such activities.

Non-personal information is necessary for The Russian Travel Market Signals Platform to gather required information on the number of visitors, the pages most frequently consulted, the technology used by Website users, link selection and users' country of origin.

Cookies are fragments of information sent to your computer when a website is viewed. These are traces of the user's visit that are recorded either temporarily or permanently on their hard drive and may include the date and time of the last visit, among other things. Cookies contribute to improving users' online experience by recording browsing preferences on a particular website.

Cookies left on users' hard drive are harmless and may be read or deleted at any time. Users therefore have complete control over them. The information allows us to determine the total number of visitors to each web page and the time spent on it. Every time users go to the Website, a cookie is created and left on their computer, therefore allowing The Russian Travel Market Signals Platform to "recognize" them.

Many major websites use cookies, and most browsers are configured to allow cookies. The user may choose to change their browser settings so that a message is automatically sent to ask whether to accept or refuse cookies. While users are not required to accept cookies, they should be aware that certain Website functionalities may not work properly if cookies are refused.

9. LINKS TO THIRD-PARTY SITES

The Website may contain links to third-party sites ("Third-Party Sites") via which the user will leave the Website. The Russian Travel Market Signals Platform provides these links for the user's convenience. The Russian Travel Market Signals Platform has no control over the content and use of such sites, nor on their practices relating to privacy and confidentiality. Therefore, any confidential or personal information provided through those sites will be subject to that site's privacy policy. It is the user's responsibility to consult such policies to ensure the privacy of their information.

10. QUESTIONS, COMMENT OR SUGGESTIONS

If you have questions, comments or suggestions regarding this Confidentiality Policy or The Russian Travel Market Signals Platform practices relating to privacy that are not covered by this Confidentiality Policy, contact us at hello@travel-analytics.ru.