1. General Provisions
This personal data processing policy is developed in accordance with Federal Law No. 152-FZ, dated July 27, 2006, On Personal Data. This policy determines the procedure of personal data processing and measures to ensure personal data protection undertaken by MILEONAIR (hereinafter referred to as Operator).
1.1. The purpose and goal of Operator’s activities is to ensure the observance of human and civil rights and liberties while processing user personal data, including the right to privacy, personal and family secrecy.
1.2. Operator shall comply with personal data processing principles and conditions enshrined in relevant laws of the Russian Federation.
1.3. This personal data processing policy of Operator (hereinafter referred to as Policy) shall apply to all information Operator may receive about the visitors of the website http://www.mileonair.com and MILEONAIR’s app users.
2. Basic Terms and Definitions
2.1. Automated Personal Data Processing — personal data processing by means of computer technology;
2.2. Blocking of Personal Data — temporary cessation of personal data processing (with the exception of cases when processing is required for personal data specification);
2.3. Website — a set of graphic and information materials, as well as software and databases ensuring their availability on the Internet at the network address http://www.mileonair.com;
2.4. MILEONAIR Mobile App — software for mobile devices providing the user with an opportunity to receive unique marketing offers;
2.5. Personal Data Information System — a set of personal data included into personal information databases, as well as software and hardware used for their processing;
2.6. Personal Data Anonymization — process of removing personally identifiable information from data sets so that the identity of a User or any other personal data subject cannot be verified without using additional information;
2.7. Personal Data Processing — any action (operation) or a series of actions (operations) with personal data performed with or without automation, including collection, recording, systematization, accumulation, storage, specification (updates, alterations), extraction, use, transfer (dissemination, presentation, access), anonymization, blocking, removal and destruction of personal data;
2.8. Operator — a state agency, municipal authority, legal entity or person that independently or in cooperation with other entities organizes and/or processes personal data as well as determines the purposes and scope of personal data processing and actions (operations) performed with personal data;
2.9. Personal Data — any information referring directly or indirectly to a particular or identified User of http://www.mileonair.com or MILEONAIR’s mobile app;
2.10. User — any visitor of http://www.mileonair.com or MILEONAIR’s mobile app.
2.11. Personal Data Provision — actions aimed at disclosure of personal data to a particular person or group of persons.
2.12. Personal Data Distribution — any actions aimed at disclosure of personal data to an unspecified group of persons (transfer of personal data) or making personal data available to the general public;
2.13. Cross-Border Personal Data Transfer — transfer of personal data to a foreign state agency, a foreign person or legal entity located in another country;
2.14. Personal Data Destruction — any actions making it impossible to retrieve and recover personal data contained in the personal data system and/or destruction of tangible carriers of personal data.
3. Operator shall process the following personal user data:
3.1. first and last name, patronymic;
3.3. telephone numbers;
3.4. year, month, date and place of birth;
3.6. device location data
3.7. the website also collects and processes anonymized user data (including cookies) using web analytics services (Yandex.Metrica, Google Analytics and others).
The afore-mentioned data shall be hereinafter referred to as Personal Data in this Policy.
4. Purposes of Personal Data Processing
4.1. Purpose of processing user personal data is to provide information to User via e-mails, SMS newsletters and push notifications.
4.2. With the permission of the user this app collects device location data when the app is open and in use to identify the nearest airport and to show a list of current offers. With the permission of the user this app may also collect device location data when the app is closed or not in use to know when the user gets to the airport and to notify that he could use the app.
4.3. Operator reserves the right to send user notifications about new products and services, special offers and various events. User can always unsubscribe from newsletters by sending an e-mail to Operator at email@example.com with the text Unsubscribe from notifications about new products and special offers.
4.4. Anonymized user data gathered via web analytics services is used to collect information about user activities on the website and improve the website’s quality and content.
5. Legal Basis for Personal Data Processing
5.1. Operator shall process user personal data only if the user fills in and/or sends the data using special forms found at http://www.mileonair.com or on MILEONAIR’s mobile app. By filling in and/or sending personal data to Operator, User consents to this Policy.
6. Collection, Storage, Transfer and Other Kinds of Personal Data Processing
Protection of personal data processed by Operator shall be ensured through the implementation of legal, organizational and technical measures required to fully comply with the existing personal data protection laws.
6.1. Operator shall ensure personal data security and undertake all the possible measures to exclude access to personal data by unauthorized persons.
6.2. User personal data shall not be transferred to third parties under any circumstances, unless required by the laws of the Russian Federation.
6.3. If User finds discrepancies in their personal data, they can update the data independently by sending a notification to Operator at firstname.lastname@example.org with the text Personal data update.
6.4. Personal data processing time is unlimited. User can revoke their consent to personal data processing at any time by sending a notification to Operator at email@example.com with the text Personal data processing consent withdrawal.
7. Cross-Border Transfer of Personal Data
7.1. Operator shall ensure that adequate protection of rights of personal data subjects is provided by the foreign state where data transfer is supposed to be made before starting cross-border transfer of personal data.
7.2. Cross-border transfer of personal data to foreign states that do not comply with the afore-mentioned requirements can only be made if personal data subject consents in writing to cross-border transfer of their personal data and/or it is so required for the implementation of an agreement that personal data subject is party to, as well as in other cases established by the laws of the Russian Federation.
8. Final Provisions
8.1. User can be provided with any clarifications regarding their personal data processing by contacting Operator via e-mail at firstname.lastname@example.org.
8.2. This document shall also reflect any changes in personal data processing policy made by Operator. The policy shall be effective indefinitely unless substituted by a new version.
8.3. The up-to-date version of this Policy is publicly available online at http://www.mileonair.com/privacy.
8.4. Persons guilty of violating Federal Law No. 152-FZ, dated July 27, 2006, On Personal Data, incur liability in accordance with laws of the Russian Federation.