1. General Provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, On Personal Data (hereinafter — the Personal Data Law) and defines the procedures for processing personal data and measures to ensure the security of personal data undertaken by Emirates Dreams (hereinafter — the Operator).
1.1. The Operator considers it its primary goal and condition for conducting its activities to comply with the rights and freedoms of individuals when processing their personal data, including protection of the right to privacy, personal, and family confidentiality.
1.2. This Operator policy regarding personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://emirate-dreams.com/ .
2. Key Terms Used in the Policy
2.1. Automated personal data processing — processing of personal data using computer technology.
2.2. Personal data blocking — temporary cessation of personal data processing (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://emirate-dreams.com/ .
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure its processing.
2.5. Personal data depersonalisation — actions making it impossible to determine the ownership of personal data by a specific User or other subject of personal data without involving additional information.
2.6. Personal data processing — any action (operation) or set of actions (operations) carried out with or without the use of automation involving personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, alteration), extraction, use, transmission (distribution, provision, providing access), depersonalisation, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who independently or jointly with others organises and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed on personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://emirate-dreams.com/ .
2.9. Personal data permitted by the subject of personal data for distribution — personal data accessible to an unlimited circle of persons 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 accordance with the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://emirate-dreams.com/ .
2.11. Personal data provision — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transmission of personal data) or acquainting an unlimited group of persons with personal data, including publication in mass media, placement in 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, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in 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. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— in the event of the personal data subject’s withdrawal of consent to the processing of personal data, as well as submission of an application requiring cessation of personal data processing, the Operator has the right to 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 compliance with the obligations provided for in the Personal Data Law and normative legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— upon request provide the subject of personal data with information concerning the processing of his/her personal data;
— organise the processing of personal data in accordance with the requirements of the current legislation of the Russian Federation;
— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorised body for protection of the rights of personal data subjects with the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— adopt legal, organisational, and technical measures to protect personal data against unauthorised or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other unlawful actions in respect of personal data;
— cease transmission (distribution, provision, providing access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other duties prescribed by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Subjects of personal data have the right to:
— obtain information concerning the processing of their personal data, except in cases provided for by the federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and must not contain personal data relating to other subjects of personal data, except in cases where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— require the Operator to clarify their personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take the measures provided by law to protect their rights;
— demand prior consent for the processing of personal data for marketing purposes;
— withdraw consent for personal data processing, as well as submit a request for cessation of personal data processing;
— appeal to the authorised body for protection of the rights of personal data subjects or to the court against unlawful actions or omissions of the Operator when processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obligated to:
— provide the Operator with reliable information about themselves;
— notify the Operator of any updates (changes) to their personal data.
4.3. Persons who provide the Operator with unreliable information about themselves or information about another subject of personal data without that person's consent bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined and legitimate purposes. It is not permissible to process personal data in a manner incompatible with the purposes for which the personal data was collected.
5.3. The merging of databases containing personal data that are processed for purposes incompatible with each other is prohibited.
5.4. Only personal data that corresponds to the purposes of its processing shall be subject to processing.
5.5. The content and scope of processed personal data must correspond to the stated purposes of processing. There shall be no excessiveness of processed personal data in relation to the stated purposes of their processing.
5.6. When processing personal data, the accuracy, sufficiency, and where necessary, the relevance of personal data in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures or ensures their implementation regarding the removal or clarification of incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows 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 or a contract, of which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalised upon achieving the purposes of processing or when there is no longer a need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User via email
Personal data: surname, name, patronymic, email address, telephone numbers
Legal basis: Federal Law No. 149-FZ of July 27, 2006, On Information, Information Technologies and Protection of Information
Types of personal data processing: collection, recording, systematisation, accumulation, storage, destruction, and depersonalisation of personal data; sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject for processing his/her personal data.
7.2. Personal data processing is necessary for achieving goals stipulated by an international treaty of the Russian Federation or by law, for performing functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for administering justice, enforcing a judicial act, an act of another body or official, in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for fulfilling a contract in 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. Personal data processing is necessary for exercising rights and legitimate interests of the Operator or third parties or for achieving socially significant goals, provided that such processing does not violate the rights and freedoms of the personal data subject.
7.6. Personal data processing is conducted where access to such data has been granted by the personal data subject or upon his/her request (hereinafter — publicly accessible personal data).
7.7. Personal data processing is carried out where such data is subject to publication or mandatory disclosure under federal law.
8. Procedure for Collecting, Storing, Transferring and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organisational, 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 safety of personal data and takes all possible measures to prevent unauthorised 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 compliance with current legislation or if the subject of personal data has given consent to the Operator for transferring data to a third party for fulfilling obligations under a civil law contract.
8.3. In case of identifying inaccuracies in personal data, the User may update them independently by sending the Operator a notification to the Operator’s email address info@emirate-dreams.com marked as "Updating personal data".
8.4. The period of personal data processing is determined by achieving the purposes for which the personal data was collected, unless otherwise specified by the contract or current legislation. The User can withdraw their consent for personal data processing at any time by sending the Operator a notification via email to the Operator’s email address info@emirate-dreams.com marked as "Withdrawal of consent for personal data processing".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data should familiarise themselves with these documents. The Operator is not liable for actions of third parties, including the service providers mentioned in this section.
8.6. Prohibitions on transfer (except providing access), as well as on processing or conditions of processing (except obtaining access) of personal data permitted for distribution, established by the subject of personal data, do not apply in cases of processing of 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 it.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject no longer than required for the purposes of personal data processing, unless the storage period of personal data is established by federal law or a contract, of which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating the processing of personal data may include achieving the purposes of personal data processing, expiration of the consent of the subject of personal data, withdrawal of consent by the personal data subject, or a request to cease personal data processing, as well as detection of unlawful personal data processing.
9. List of Actions Performed by the Operator With Obtained Personal Data
9.1. The Operator carries out collection, recording, systematisation, accumulation, storage, clarification (updating, alteration), extraction, use, transfer (distribution, provision, providing access), depersonalisation, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated personal data processing with receipt and/or transmission of the obtained information via telecommunication networks or without such transmission.
10. Cross-border Transfer of Personal Data
10.1. The Operator must notify the authorised body for protection of personal data subjects' rights about its intention to carry out cross-border personal data transfer before starting activities related to such transfer (such notification is submitted separately from the notification about the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator must obtain relevant information from foreign state authorities, foreign individuals, or foreign legal entities intended to receive cross-border personal data transfer.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obligated not to disclose 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 regarding issues concerning the processing of his/her personal data by contacting the Operator via email at info@emirate-dreams.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely accessible online at https://emirate-dreams.com/privacy-policy/ .
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, On Personal Data (hereinafter — the Personal Data Law) and defines the procedures for processing personal data and measures to ensure the security of personal data undertaken by Emirates Dreams (hereinafter — the Operator).
1.1. The Operator considers it its primary goal and condition for conducting its activities to comply with the rights and freedoms of individuals when processing their personal data, including protection of the right to privacy, personal, and family confidentiality.
1.2. This Operator policy regarding personal data processing (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://emirate-dreams.com/ .
2. Key Terms Used in the Policy
2.1. Automated personal data processing — processing of personal data using computer technology.
2.2. Personal data blocking — temporary cessation of personal data processing (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://emirate-dreams.com/ .
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure its processing.
2.5. Personal data depersonalisation — actions making it impossible to determine the ownership of personal data by a specific User or other subject of personal data without involving additional information.
2.6. Personal data processing — any action (operation) or set of actions (operations) carried out with or without the use of automation involving personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating, alteration), extraction, use, transmission (distribution, provision, providing access), depersonalisation, blocking, deletion, destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual who independently or jointly with others organises and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and actions (operations) performed on personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://emirate-dreams.com/ .
2.9. Personal data permitted by the subject of personal data for distribution — personal data accessible to an unlimited circle of persons 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 accordance with the Personal Data Law (hereinafter — personal data permitted for distribution).
2.10. User — any visitor to the website https://emirate-dreams.com/ .
2.11. Personal data provision — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transmission of personal data) or acquainting an unlimited group of persons with personal data, including publication in mass media, placement in 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, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in 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. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— in the event of the personal data subject’s withdrawal of consent to the processing of personal data, as well as submission of an application requiring cessation of personal data processing, the Operator has the right to 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 compliance with the obligations provided for in the Personal Data Law and normative legal acts adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
— upon request provide the subject of personal data with information concerning the processing of his/her personal data;
— organise the processing of personal data in accordance with the requirements of the current legislation of the Russian Federation;
— respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorised body for protection of the rights of personal data subjects with the necessary information within 10 days from the date of receipt of such a request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— adopt legal, organisational, and technical measures to protect personal data against unauthorised or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as other unlawful actions in respect of personal data;
— cease transmission (distribution, provision, providing access) of personal data, cease processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other duties prescribed by the Personal Data Law.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Subjects of personal data have the right to:
— obtain information concerning the processing of their personal data, except in cases provided for by the federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and must not contain personal data relating to other subjects of personal data, except in cases where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
— require the Operator to clarify their personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, as well as take the measures provided by law to protect their rights;
— demand prior consent for the processing of personal data for marketing purposes;
— withdraw consent for personal data processing, as well as submit a request for cessation of personal data processing;
— appeal to the authorised body for protection of the rights of personal data subjects or to the court against unlawful actions or omissions of the Operator when processing their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obligated to:
— provide the Operator with reliable information about themselves;
— notify the Operator of any updates (changes) to their personal data.
4.3. Persons who provide the Operator with unreliable information about themselves or information about another subject of personal data without that person's consent bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data processing is carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined and legitimate purposes. It is not permissible to process personal data in a manner incompatible with the purposes for which the personal data was collected.
5.3. The merging of databases containing personal data that are processed for purposes incompatible with each other is prohibited.
5.4. Only personal data that corresponds to the purposes of its processing shall be subject to processing.
5.5. The content and scope of processed personal data must correspond to the stated purposes of processing. There shall be no excessiveness of processed personal data in relation to the stated purposes of their processing.
5.6. When processing personal data, the accuracy, sufficiency, and where necessary, the relevance of personal data in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures or ensures their implementation regarding the removal or clarification of incomplete or inaccurate data.
5.7. Storage of personal data is carried out in a form that allows 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 or a contract, of which the personal data subject is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalised upon achieving the purposes of processing or when there is no longer a need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: informing the User via email
Personal data: surname, name, patronymic, email address, telephone numbers
Legal basis: Federal Law No. 149-FZ of July 27, 2006, On Information, Information Technologies and Protection of Information
Types of personal data processing: collection, recording, systematisation, accumulation, storage, destruction, and depersonalisation of personal data; sending informational emails to the email address.
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject for processing his/her personal data.
7.2. Personal data processing is necessary for achieving goals stipulated by an international treaty of the Russian Federation or by law, for performing functions, powers, and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. Personal data processing is necessary for administering justice, enforcing a judicial act, an act of another body or official, in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for fulfilling a contract in 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. Personal data processing is necessary for exercising rights and legitimate interests of the Operator or third parties or for achieving socially significant goals, provided that such processing does not violate the rights and freedoms of the personal data subject.
7.6. Personal data processing is conducted where access to such data has been granted by the personal data subject or upon his/her request (hereinafter — publicly accessible personal data).
7.7. Personal data processing is carried out where such data is subject to publication or mandatory disclosure under federal law.
8. Procedure for Collecting, Storing, Transferring and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organisational, 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 safety of personal data and takes all possible measures to prevent unauthorised 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 compliance with current legislation or if the subject of personal data has given consent to the Operator for transferring data to a third party for fulfilling obligations under a civil law contract.
8.3. In case of identifying inaccuracies in personal data, the User may update them independently by sending the Operator a notification to the Operator’s email address info@emirate-dreams.com marked as "Updating personal data".
8.4. The period of personal data processing is determined by achieving the purposes for which the personal data was collected, unless otherwise specified by the contract or current legislation. The User can withdraw their consent for personal data processing at any time by sending the Operator a notification via email to the Operator’s email address info@emirate-dreams.com marked as "Withdrawal of consent for personal data processing".
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data should familiarise themselves with these documents. The Operator is not liable for actions of third parties, including the service providers mentioned in this section.
8.6. Prohibitions on transfer (except providing access), as well as on processing or conditions of processing (except obtaining access) of personal data permitted for distribution, established by the subject of personal data, do not apply in cases of processing of 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 it.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject no longer than required for the purposes of personal data processing, unless the storage period of personal data is established by federal law or a contract, of which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating the processing of personal data may include achieving the purposes of personal data processing, expiration of the consent of the subject of personal data, withdrawal of consent by the personal data subject, or a request to cease personal data processing, as well as detection of unlawful personal data processing.
9. List of Actions Performed by the Operator With Obtained Personal Data
9.1. The Operator carries out collection, recording, systematisation, accumulation, storage, clarification (updating, alteration), extraction, use, transfer (distribution, provision, providing access), depersonalisation, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated personal data processing with receipt and/or transmission of the obtained information via telecommunication networks or without such transmission.
10. Cross-border Transfer of Personal Data
10.1. The Operator must notify the authorised body for protection of personal data subjects' rights about its intention to carry out cross-border personal data transfer before starting activities related to such transfer (such notification is submitted separately from the notification about the intention to process personal data).
10.2. Before submitting the aforementioned notification, the Operator must obtain relevant information from foreign state authorities, foreign individuals, or foreign legal entities intended to receive cross-border personal data transfer.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obligated not to disclose 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 regarding issues concerning the processing of his/her personal data by contacting the Operator via email at info@emirate-dreams.com.
12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely accessible online at https://emirate-dreams.com/privacy-policy/ .