Personal Data
Processing Policy
Processing Policy
Date of Approval: 13.10.2026
1. General Provisions
1.1. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) establishes the procedures and conditions for processing personal data, as well as the measures taken to ensure their security, applied by Individual Entrepreneur Zhirair Pogosovich Sogoyan (hereinafter referred to as the “Operator”).
1.2. This Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of July 27, 2006, “On Personal Data,” and other regulatory legal acts of the Russian Federation governing the processing and protection of personal data.
1.3. Information about the Operator:
1.5. The Operator ensures public access to this Policy by publishing it on the hotel's official website.
1.6. Reviewing this Policy does not, in itself, constitute consent to the processing of personal data. Where processing is carried out on the basis of the data subject's consent, such consent shall be obtained separately from other documents and information in accordance with the legislation of the Russian Federation.
2. Key Definitions
2.1. Personal Data - any information relating directly or indirectly to an identified or identifiable natural person.
2.2. Personal Data Subject - a natural person to whom the processed personal data relates.
2.3. Processing of Personal Data - any operation or set of operations performed on personal data, whether by automated means or otherwise, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, and destruction.
2.4. Personal Data Operator — a person who, independently or jointly with other persons, organizes and carries out the processing of personal data and determines the purposes of such processing, the categories of data to be processed, and the operations performed on such data.
2.5. Automated Processing of Personal Data — processing of personal data using computing technology.
2.6. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.7. Anonymization of Personal Data — actions resulting in the inability to identify the personal data as belonging to a specific data subject without the use of additional information.
2.8. Destruction of Personal Data — actions resulting in the inability to restore the contents of personal data in a personal data information system and/or the destruction of physical media containing personal data.
2.9. Cross-Border Transfer of Personal Data — the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign natural person, or a foreign legal entity.
3. Principles of Personal Data Processing
3.1. Personal data shall be processed on a lawful and fair basis.
3.2. Processing shall be limited to achieving specific, predetermined, and legitimate purposes.
3.3. Processing of personal data that is incompatible with the purposes for which the data was originally collected is not permitted.
3.4. The categories and volume of personal data processed must correspond to the stated purposes of processing. Processing excessive personal data is not permitted.
3.5. The Operator shall take the necessary measures to ensure the accuracy, adequacy, and currency of personal data.
3.6. Personal data shall not be stored longer than required for the purposes of processing, unless a different retention period is established by the legislation of the Russian Federation or by contract.
3.7. Upon achievement of the purposes of processing, personal data shall be deleted, destroyed, or anonymized unless further processing is required in accordance with the legislation of the Russian Federation.
4. Purposes, Categories, and Legal Grounds for Personal Data Processing
The Operator processes personal data for the following purposes.
4.1. Reservation Processing and Fulfillment
Purpose: To receive and process room reservation requests, confirm, modify, and cancel reservations, inform guests about accommodation conditions, and fulfill contractual obligations.
Categories of Data Subjects: Individuals making reservations, hotel guests, and representatives of customers purchasing hotel services.
Personal Data Processed:
Where the consent of the personal data subject is required for a specific processing operation, such consent shall be obtained separately.
4.2. Provision of Hotel Services and Compliance with Legal Requirements
Purpose: To register guests for accommodation, verify their identity, carry out mandatory registration and migration record-keeping, and maintain documentation required by the legislation of the Russian Federation.
Categories of Data Subjects: Hotel guests, including minors in cases provided for by law.
Personal Data Processed: Surname, first name, patronymic, date of birth, citizenship, details of identity documents, registered address, information regarding the duration and conditions of accommodation, and other data necessary to fulfill statutory obligations.
Legal Basis: Clauses 2 and 5, Part 1, Article 6 of Federal Law No. 152-FZ; applicable regulatory legal acts of the Russian Federation governing the provision of hotel services, registration and migration record-keeping; and concluded contracts.
4.3. Handling Inquiries and Feedback
Purpose: To receive and review questions, suggestions, applications, complaints, and other inquiries related to the hotel's activities.
Personal Data Processed: Name, contact telephone number, email address, contents of the inquiry, and other information voluntarily provided by the applicant.
Legal Basis: Performance of a contract, fulfillment of the Operator's statutory obligations, or consent of the personal data subject, depending on the content and nature of the inquiry.
4.4. Sending Advertising and Informational Communications
Purpose: To provide information about special offers, promotions, discounts, hotel news, and other advertising materials.
Personal Data Processed: Surname, first name, patronymic (if applicable), telephone number, and email address.
Legal Basis: Prior consent of the recipient to receive advertising communications and the corresponding consent to the processing of personal data.
Consent to receive advertising communications shall be obtained separately, shall be voluntary, and shall not constitute a mandatory condition for making a reservation.
The personal data subject has the right to opt out of receiving advertising communications at any time.
Service-related messages directly associated with an existing reservation or the performance of a contract shall not be considered advertising communications, provided that they do not contain advertising.
4.5. Website Traffic Analysis and Improvement
Purpose: To analyze website traffic, study visitors' interactions with website pages, identify technical errors, and improve website performance.
Personal Data Processed: IP address, browser and device information, cookie data, information about pages visited, visitor actions, and other technical information collected through web analytics tools.
Legal Basis: Applicable provisions of Article 6 of Federal Law No. 152-FZ, including the consent of the personal data subject where such consent is required for the relevant processing activities.
The Operator acknowledges that technical identifiers and information about visitors' actions may constitute personal data if they allow a natural person to be identified directly or indirectly.
5. Use of the TravelLine Online Booking Service
5.1. The Operator's website uses TravelLine: Booking Engine software to enable users to book hotel services online.
5.2. Personal data processing within this service involves:
TRAVEL LINE SYSTEMS LLC (ООО «ТРЭВЕЛ ЛАЙН СИСТЕМС»)
5.4. The Operator engages TRAVEL LINE SYSTEMS LLC to process personal data on grounds provided for by law, including in accordance with contractual relations between the parties.
5.5. When making a reservation, the user is provided with separate documents relating to the use of the TravelLine module, including consent to personal data processing, a user agreement, and the platform's privacy policy.
5.6. The use of TravelLine does not exempt the Operator from fulfilling its obligations under Federal Law No. 152-FZ with respect to personal data processed on the Operator's behalf.
5.7. Payment service providers may be used when processing reservation payments. Payment data shall be processed to the extent necessary to complete payments, in compliance with legal requirements and the terms of the relevant payment services.
6. Use of Cookies and Yandex Metrica
6.1. The website https://armathotel.ru/ uses cookies and web analytics technologies.
6.2. Cookies are small pieces of data stored by the browser on the user's device. They may be used to ensure website functionality, save technical settings, and analyze visitors' interactions with the website.
6.3. The website uses the Yandex Metrica web analytics service provided by Yandex LLC (ООО «Яндекс»).
6.4. Depending on the Yandex Metrica settings, information about the visitor's device and browser, IP address, technical identifiers, data about pages visited, and user actions on the website may be processed.
6.5. The information obtained is used to analyze website traffic, assess website performance, and improve its structure, content, and user experience.
6.6. The use of cookies may include:
6.8. If prior user consent is required for the use of certain cookies and analytics technologies, the Operator is obliged to arrange for such consent to be obtained in an appropriate manner.
6.9. Additional information about the Yandex Metrica service is available on its official website: https://yandex.ru/support/metrica/.
6.10. The Operator does not regard the mere act of visiting the website, continuing to use it, or having browser settings that allow cookies to be stored as universal consent to any operations involving personal data.
7. Procedures and Conditions for Personal Data Processing
7.1. The Operator processes personal data using automated and non-automated methods.
7.2. Depending on the purpose of processing, the Operator may collect, record, systematize, accumulate, store, update, retrieve, use, provide, anonymize, block, delete, and destroy personal data.
7.3. Personal data processing shall be carried out where legal grounds provided for by legislation exist.
7.4. Personal data may be transferred to third parties in the following cases:
7.6. When entrusting personal data processing to a third party, the Operator shall ensure compliance with the requirements of Part 3, Article 6 of Federal Law No. 152-FZ.
7.7. The transfer of personal data for advertising purposes shall be carried out only where an appropriate legal basis exists.
7.8. The Operator shall not disseminate personal data to an unlimited number of persons without a legal basis provided for by legislation.
8. Retention Periods and Termination of Personal Data Processing
8.1. The period of personal data processing and storage shall be determined by the specific purpose of processing, applicable requirements of the legislation of the Russian Federation, and the terms of concluded contracts.
8.2. Data related to reservations and the provision of hotel services shall be processed for the period necessary to fulfill the relevant obligations and, after their completion, within the mandatory retention periods established by the legislation of the Russian Federation.
8.3. Personal data used exclusively for advertising communications shall be processed until the relevant purpose has been achieved, the consent has expired, or the consent has been withdrawn, provided that no other legal basis exists for continuing the processing.
8.4. Data provided in connection with inquiries shall be processed for the period necessary to review the inquiry, fulfill related obligations, and comply with applicable legal requirements.
8.5. Retention periods for technical data and cookies shall be established taking into account the purposes of their use, the settings of the relevant services, and legal requirements.
8.6. Personal data processing shall be terminated in the following cases:
8.8. Personal data shall be destroyed using methods that prevent its subsequent recovery, in compliance with the requirements established by legislation.
9. Ensuring Personal Data Security
9.1. The Operator shall implement legal, organizational, and technical measures aimed at protecting personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions.
9.2. When organizing personal data processing, the Operator is obliged to ensure:
9.4. The Operator shall ensure compliance with the applicable requirements of the legislation of the Russian Federation concerning the use of databases when collecting personal data of citizens of the Russian Federation.
10. Cross-Border Transfer of Personal Data
10.1. Cross-border transfers of personal data shall be carried out where lawful grounds exist and in compliance with the requirements of Article 12 of Federal Law No. 152-FZ.
10.2. Before commencing cross-border transfers of personal data, the Operator is obliged to complete the procedures prescribed by legislation, including submitting a separate notification to the authorized body responsible for protecting the rights of personal data subjects, if such transfers are envisaged.
10.3. When organizing cross-border transfers, the Operator shall take into account the conditions, restrictions, and requirements established by legislation concerning the protection of the personal data being transferred.
10.4. The integration of external technical services does not, in itself, constitute a cross-border transfer of personal data. Whether such a transfer takes place shall be determined by the actual circumstances of processing, including the location of the recipients and the nature of the information transferred.
11. Rights of Personal Data Subjects
11.1. A personal data subject has the right to:
11.4. The Operator shall review requests and provide responses within the time limits established by Federal Law No. 152-FZ.
11.5. In the event of withdrawal of consent, personal data processing may continue without the data subject's consent if independent legal grounds for such processing exist under Federal Law No. 152-FZ or other federal laws.
12. Final Provisions
12.1. This Policy shall be made publicly available on the official website of Armat Hotel: https://armathotel.ru/.
12.2. This Policy may be amended in connection with updates to the legislation of the Russian Federation, changes in the technologies used, integration of new services, or changes in personal data processing procedures.
12.3. A new version of this Policy shall enter into force on the date of its approval and publication, unless a different effective date is specified therein.
12.4. The current version of this Policy shall be made freely available to website visitors for review.
12.5. All matters relating to personal data processing that are not regulated by this Policy shall be governed by the applicable legislation of the Russian Federation.
1. General Provisions
1.1. This Personal Data Processing Policy (hereinafter referred to as the “Policy”) establishes the procedures and conditions for processing personal data, as well as the measures taken to ensure their security, applied by Individual Entrepreneur Zhirair Pogosovich Sogoyan (hereinafter referred to as the “Operator”).
1.2. This Policy has been developed in accordance with the Constitution of the Russian Federation, Federal Law No. 152-FZ of July 27, 2006, “On Personal Data,” and other regulatory legal acts of the Russian Federation governing the processing and protection of personal data.
1.3. Information about the Operator:
- Name: Individual Entrepreneur Zhirair Pogosovich Sogoyan
- Taxpayer Identification Number (INN): 381204442417
- Primary State Registration Number of Individual Entrepreneur (OGRNIP): 319385000044370
- Address: 33 Shiryamova Street, Irkutsk, Irkutsk Region, 664009, Russian Federation
- Website: https://armathotel.ru/
- Email: info@armathotel.ru
- Reservations Department Email: booking@armathotel.ru
1.5. The Operator ensures public access to this Policy by publishing it on the hotel's official website.
1.6. Reviewing this Policy does not, in itself, constitute consent to the processing of personal data. Where processing is carried out on the basis of the data subject's consent, such consent shall be obtained separately from other documents and information in accordance with the legislation of the Russian Federation.
2. Key Definitions
2.1. Personal Data - any information relating directly or indirectly to an identified or identifiable natural person.
2.2. Personal Data Subject - a natural person to whom the processed personal data relates.
2.3. Processing of Personal Data - any operation or set of operations performed on personal data, whether by automated means or otherwise, including collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer, anonymization, blocking, deletion, and destruction.
2.4. Personal Data Operator — a person who, independently or jointly with other persons, organizes and carries out the processing of personal data and determines the purposes of such processing, the categories of data to be processed, and the operations performed on such data.
2.5. Automated Processing of Personal Data — processing of personal data using computing technology.
2.6. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.7. Anonymization of Personal Data — actions resulting in the inability to identify the personal data as belonging to a specific data subject without the use of additional information.
2.8. Destruction of Personal Data — actions resulting in the inability to restore the contents of personal data in a personal data information system and/or the destruction of physical media containing personal data.
2.9. Cross-Border Transfer of Personal Data — the transfer of personal data to the territory of a foreign state, to a foreign state authority, a foreign natural person, or a foreign legal entity.
3. Principles of Personal Data Processing
3.1. Personal data shall be processed on a lawful and fair basis.
3.2. Processing shall be limited to achieving specific, predetermined, and legitimate purposes.
3.3. Processing of personal data that is incompatible with the purposes for which the data was originally collected is not permitted.
3.4. The categories and volume of personal data processed must correspond to the stated purposes of processing. Processing excessive personal data is not permitted.
3.5. The Operator shall take the necessary measures to ensure the accuracy, adequacy, and currency of personal data.
3.6. Personal data shall not be stored longer than required for the purposes of processing, unless a different retention period is established by the legislation of the Russian Federation or by contract.
3.7. Upon achievement of the purposes of processing, personal data shall be deleted, destroyed, or anonymized unless further processing is required in accordance with the legislation of the Russian Federation.
4. Purposes, Categories, and Legal Grounds for Personal Data Processing
The Operator processes personal data for the following purposes.
4.1. Reservation Processing and Fulfillment
Purpose: To receive and process room reservation requests, confirm, modify, and cancel reservations, inform guests about accommodation conditions, and fulfill contractual obligations.
Categories of Data Subjects: Individuals making reservations, hotel guests, and representatives of customers purchasing hotel services.
Personal Data Processed:
- surname, first name, and patronymic (if applicable);
- contact telephone number;
- email address;
- citizenship;
- check-in and check-out dates;
- number of guests;
- selected room category;
- information about preferences and additional services;
- other information required for a specific reservation.
Where the consent of the personal data subject is required for a specific processing operation, such consent shall be obtained separately.
4.2. Provision of Hotel Services and Compliance with Legal Requirements
Purpose: To register guests for accommodation, verify their identity, carry out mandatory registration and migration record-keeping, and maintain documentation required by the legislation of the Russian Federation.
Categories of Data Subjects: Hotel guests, including minors in cases provided for by law.
Personal Data Processed: Surname, first name, patronymic, date of birth, citizenship, details of identity documents, registered address, information regarding the duration and conditions of accommodation, and other data necessary to fulfill statutory obligations.
Legal Basis: Clauses 2 and 5, Part 1, Article 6 of Federal Law No. 152-FZ; applicable regulatory legal acts of the Russian Federation governing the provision of hotel services, registration and migration record-keeping; and concluded contracts.
4.3. Handling Inquiries and Feedback
Purpose: To receive and review questions, suggestions, applications, complaints, and other inquiries related to the hotel's activities.
Personal Data Processed: Name, contact telephone number, email address, contents of the inquiry, and other information voluntarily provided by the applicant.
Legal Basis: Performance of a contract, fulfillment of the Operator's statutory obligations, or consent of the personal data subject, depending on the content and nature of the inquiry.
4.4. Sending Advertising and Informational Communications
Purpose: To provide information about special offers, promotions, discounts, hotel news, and other advertising materials.
Personal Data Processed: Surname, first name, patronymic (if applicable), telephone number, and email address.
Legal Basis: Prior consent of the recipient to receive advertising communications and the corresponding consent to the processing of personal data.
Consent to receive advertising communications shall be obtained separately, shall be voluntary, and shall not constitute a mandatory condition for making a reservation.
The personal data subject has the right to opt out of receiving advertising communications at any time.
Service-related messages directly associated with an existing reservation or the performance of a contract shall not be considered advertising communications, provided that they do not contain advertising.
4.5. Website Traffic Analysis and Improvement
Purpose: To analyze website traffic, study visitors' interactions with website pages, identify technical errors, and improve website performance.
Personal Data Processed: IP address, browser and device information, cookie data, information about pages visited, visitor actions, and other technical information collected through web analytics tools.
Legal Basis: Applicable provisions of Article 6 of Federal Law No. 152-FZ, including the consent of the personal data subject where such consent is required for the relevant processing activities.
The Operator acknowledges that technical identifiers and information about visitors' actions may constitute personal data if they allow a natural person to be identified directly or indirectly.
5. Use of the TravelLine Online Booking Service
5.1. The Operator's website uses TravelLine: Booking Engine software to enable users to book hotel services online.
5.2. Personal data processing within this service involves:
TRAVEL LINE SYSTEMS LLC (ООО «ТРЭВЕЛ ЛАЙН СИСТЕМС»)
- Taxpayer Identification Number (INN): 1215180595
- Primary State Registration Number (OGRN): 1141215003214
- Address: 112 Komsomolskaya Street, Yoshkar-Ola, Republic of Mari El, 424031, Russian Federation.
5.4. The Operator engages TRAVEL LINE SYSTEMS LLC to process personal data on grounds provided for by law, including in accordance with contractual relations between the parties.
5.5. When making a reservation, the user is provided with separate documents relating to the use of the TravelLine module, including consent to personal data processing, a user agreement, and the platform's privacy policy.
5.6. The use of TravelLine does not exempt the Operator from fulfilling its obligations under Federal Law No. 152-FZ with respect to personal data processed on the Operator's behalf.
5.7. Payment service providers may be used when processing reservation payments. Payment data shall be processed to the extent necessary to complete payments, in compliance with legal requirements and the terms of the relevant payment services.
6. Use of Cookies and Yandex Metrica
6.1. The website https://armathotel.ru/ uses cookies and web analytics technologies.
6.2. Cookies are small pieces of data stored by the browser on the user's device. They may be used to ensure website functionality, save technical settings, and analyze visitors' interactions with the website.
6.3. The website uses the Yandex Metrica web analytics service provided by Yandex LLC (ООО «Яндекс»).
6.4. Depending on the Yandex Metrica settings, information about the visitor's device and browser, IP address, technical identifiers, data about pages visited, and user actions on the website may be processed.
6.5. The information obtained is used to analyze website traffic, assess website performance, and improve its structure, content, and user experience.
6.6. The use of cookies may include:
- technical cookies necessary for the operation of the website and its individual services;
- analytical cookies used for statistical analysis of website traffic and user actions.
6.8. If prior user consent is required for the use of certain cookies and analytics technologies, the Operator is obliged to arrange for such consent to be obtained in an appropriate manner.
6.9. Additional information about the Yandex Metrica service is available on its official website: https://yandex.ru/support/metrica/.
6.10. The Operator does not regard the mere act of visiting the website, continuing to use it, or having browser settings that allow cookies to be stored as universal consent to any operations involving personal data.
7. Procedures and Conditions for Personal Data Processing
7.1. The Operator processes personal data using automated and non-automated methods.
7.2. Depending on the purpose of processing, the Operator may collect, record, systematize, accumulate, store, update, retrieve, use, provide, anonymize, block, delete, and destroy personal data.
7.3. Personal data processing shall be carried out where legal grounds provided for by legislation exist.
7.4. Personal data may be transferred to third parties in the following cases:
- when the transfer is necessary for the performance of a contract with the personal data subject;
- when processing has been entrusted to a third party on lawful grounds;
- when the transfer is required by the legislation of the Russian Federation;
- when the personal data subject has provided the necessary consent;
- in other cases provided for by the legislation of the Russian Federation.
7.6. When entrusting personal data processing to a third party, the Operator shall ensure compliance with the requirements of Part 3, Article 6 of Federal Law No. 152-FZ.
7.7. The transfer of personal data for advertising purposes shall be carried out only where an appropriate legal basis exists.
7.8. The Operator shall not disseminate personal data to an unlimited number of persons without a legal basis provided for by legislation.
8. Retention Periods and Termination of Personal Data Processing
8.1. The period of personal data processing and storage shall be determined by the specific purpose of processing, applicable requirements of the legislation of the Russian Federation, and the terms of concluded contracts.
8.2. Data related to reservations and the provision of hotel services shall be processed for the period necessary to fulfill the relevant obligations and, after their completion, within the mandatory retention periods established by the legislation of the Russian Federation.
8.3. Personal data used exclusively for advertising communications shall be processed until the relevant purpose has been achieved, the consent has expired, or the consent has been withdrawn, provided that no other legal basis exists for continuing the processing.
8.4. Data provided in connection with inquiries shall be processed for the period necessary to review the inquiry, fulfill related obligations, and comply with applicable legal requirements.
8.5. Retention periods for technical data and cookies shall be established taking into account the purposes of their use, the settings of the relevant services, and legal requirements.
8.6. Personal data processing shall be terminated in the following cases:
- achievement of the purpose of processing;
- expiration or withdrawal of consent in the absence of other legal grounds;
- receipt of a justified request to terminate processing;
- identification of unlawful processing;
- occurrence of other circumstances provided for by the legislation of the Russian Federation.
8.8. Personal data shall be destroyed using methods that prevent its subsequent recovery, in compliance with the requirements established by legislation.
9. Ensuring Personal Data Security
9.1. The Operator shall implement legal, organizational, and technical measures aimed at protecting personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions.
9.2. When organizing personal data processing, the Operator is obliged to ensure:
- determination of lawful processing purposes and the categories of data required;
- restriction of access to personal data;
- implementation of necessary measures to protect information systems;
- maintenance of personal data confidentiality;
- identification and remediation of violations of personal data legislation;
- proper organization of personal data processing by persons acting on behalf of the Operator.
9.4. The Operator shall ensure compliance with the applicable requirements of the legislation of the Russian Federation concerning the use of databases when collecting personal data of citizens of the Russian Federation.
10. Cross-Border Transfer of Personal Data
10.1. Cross-border transfers of personal data shall be carried out where lawful grounds exist and in compliance with the requirements of Article 12 of Federal Law No. 152-FZ.
10.2. Before commencing cross-border transfers of personal data, the Operator is obliged to complete the procedures prescribed by legislation, including submitting a separate notification to the authorized body responsible for protecting the rights of personal data subjects, if such transfers are envisaged.
10.3. When organizing cross-border transfers, the Operator shall take into account the conditions, restrictions, and requirements established by legislation concerning the protection of the personal data being transferred.
10.4. The integration of external technical services does not, in itself, constitute a cross-border transfer of personal data. Whether such a transfer takes place shall be determined by the actual circumstances of processing, including the location of the recipients and the nature of the information transferred.
11. Rights of Personal Data Subjects
11.1. A personal data subject has the right to:
- obtain information about the processing of their personal data;
- request the correction of incomplete, outdated, or inaccurate personal data;
- request the blocking or destruction of personal data where grounds provided for by law exist;
- withdraw previously granted consent;
- submit a request to terminate the processing of personal data;
- opt out of receiving advertising communications;
- challenge the actions or inaction of the Operator by filing a complaint with Roskomnadzor or through judicial proceedings;
- exercise other rights provided for by the legislation of the Russian Federation.
- by email: info@armathotel.ru;
- by email to the Reservations Department: booking@armathotel.ru;
- by post to the following address: 33 Shiryamova Street, Irkutsk, Irkutsk Region, 664009, Russian Federation.
11.4. The Operator shall review requests and provide responses within the time limits established by Federal Law No. 152-FZ.
11.5. In the event of withdrawal of consent, personal data processing may continue without the data subject's consent if independent legal grounds for such processing exist under Federal Law No. 152-FZ or other federal laws.
12. Final Provisions
12.1. This Policy shall be made publicly available on the official website of Armat Hotel: https://armathotel.ru/.
12.2. This Policy may be amended in connection with updates to the legislation of the Russian Federation, changes in the technologies used, integration of new services, or changes in personal data processing procedures.
12.3. A new version of this Policy shall enter into force on the date of its approval and publication, unless a different effective date is specified therein.
12.4. The current version of this Policy shall be made freely available to website visitors for review.
12.5. All matters relating to personal data processing that are not regulated by this Policy shall be governed by the applicable legislation of the Russian Federation.
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