Privacy policy

1. Terms and definitions
1.1. Website is a collection of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://wroomify.ru
1.2. Web application is software that runs in a web browser at the network address https://wroomify.app
1.3. Mobile application is software (a type of application software) specially developed for a specific platform and designed to work on smartphones, tablets and other mobile (portable, portable, pocket) devices.
1.4. Terminal is a technical terminal device (display station, display, display console) used for interaction between the User (or operator) and a computer or computer system (local or cloud technology). In this Policy, the final product is a technical device for checking in guests — the Wroomify terminal. The terminal also includes a software part in the form of a web application located at the network address https://wroomify.app
1.5. Services are a set of Operator services provided through the Operator’s software, third-party software, website — https://wroomify.app, Wroomify web or mobile application, Wroomify terminals.
1.6. Personal data is any information relating directly or indirectly to a specific or identified User of the website https://wroomify.ru, web application https://wroomify.app and mobile application Wroomify, hosted on the AppStore and Google Play Market Platforms.
1.7. Processing of personal data is any action (operation) or set of actions (operations) performed using automation tools or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.8. Confidentiality of personal data is a mandatory requirement for the responsible person who has access to personal data to prevent their dissemination without the consent of the subject or other legal basis.
1.9. Distribution of personal data are any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing with personal data to an unlimited number of persons, including the publication of personal data in the media, posting in information and telecommunication networks or providing access to personal data in any other way.
1.10. Use of personal data is actions (operations) with personal data performed for the purpose of decision-making or other actions (including advertising purposes) that give rise to legal consequences in relation to the subjects of personal data or in any other way affecting their rights and freedoms or rights and freedoms other persons.
1.11. Blocking of personal data is temporary cessation of processing of personal data (except for cases where processing is necessary to clarify personal data).
1.12. Operator is a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data. Within the framework of this Policy regarding the processing of personal data, the Operator is the legal entity Wone IT LLC.
1.13. User (subject of personal data) is an individual (visitor, consumer of services) who visited the site https://wroomify.app, using the Wroomify mobile application and other technical devices associated with Wone IT.
1.14. Reservation is a reservation of any service or product made by the User on the website https://wroomify.app
1.15. Personal data information system is a set of personal data contained in databases and information technologies and technical means that ensure their processing.
1.16. Depersonalization of personal data are actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other subject of personal data.
1.17. Providing personal data are actions aimed at disclosing personal data to a certain person or a certain circle of persons.
1.18. Cross-border transfer of personal data is transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
1.19. Destruction of personal data are any actions as a result of which personal data is destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the material media of personal data are destroyed.

2. General provisions
2.1. This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-FZ “On Personal Data” (hereinafter referred to as the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Wone IT LLC, located at the address: Russia, St. Petersburg, Volkhovskoy per., 4, 3rd floor, Wone IT office.
2.2. The operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of man and citizen when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
2.3. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about Users of Wroomify services (website https://wroomify.app, Wroomify mobile application located in the Google Play Market and AppStore and in registration and communication terminals).

3. Basic rights and obligations of the Operator
3.1. The operator has the right:

• to receive from the User reliable information and/or documents containing Personal Data;
• if the User withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the User’s consent if there are grounds specified in the Law on Personal Data;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and regulations adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws;
• defend their interests in court;
• provide Personal Data of Users to third parties, if provided for by current legislation (tax, law enforcement, etc.) or the Agreement with the User;
• use the User’s Personal Data without their consent, in cases provided for by the legislation of the Russian Federation;
• refuse to provide personal data in cases provided for by the legislation of the Russian Federation.

3.2. The operator is obliged:

• to provide the User, at their request, with information regarding the processing of their personal data;
• to organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• to respond to requests and inquiries from Users and their legal representatives in accordance with the requirements of the Personal Data Law;
• to report to the authorized body for the protection of the rights of personal data subjects, at the request of this body, the necessary information within 10 days from the date of receipt of such a request;
• to publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• to take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
• to stop transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
• to perform other duties provided for by the Personal Data Law.

4. Basic rights and obligations of the User
4.1. Users have the right:

• to receive information regarding the processing of their personal data, except for cases provided for by federal laws. The information is provided to the User by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, except in cases where there are legal grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
• to require the operator to clarify their personal data, block it or destroy it at the request of the User, as well as in the event that personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take protection measures provided for by law your rights;
• to require notification of all persons who were previously informed of incorrect or incomplete personal data about all corrections, exceptions and additions made to them;
• to withdraw consent to the processing of personal data by notifying the Operator by email support@wroomify.ru;
• to appeal to the authorized body for the protection of the rights of personal data subjects or in court the unlawful actions or inaction of the Operator when processing their personal data;
• to exercise other rights provided for by the legislation of the Russian Federation.

4.2. Users are obliged:

• to provide the Operator with reliable information about yourself;
• to provide the Operator with reliable data about third parties, if this is provided for by the functionality of the Operator’s services;
• to notify and obtain consent in principle to enter data of third parties associated with the User through the Booking;
• to respect other person's personal data and delete third party data from your account upon first request;
• to inform the Operator about clarification (updating, changing) of your personal data and data of third parties that are associated with the User through the Booking;
• to use the Operator’s services for the purposes provided for in the User Agreement or other agreements between the User and the Operator.

4.3. Persons who provided the Operator with false information about themselves or information about another subject of personal data without the latter’s consent are liable in accordance with the legislation of the Russian Federation.

5. Purposes of processing personal data
5.1. Purposes of use of personal data by the Operator:

• informing the User by sending emails, push notifications, messages;
• providing the User with access to the Operator’s services:
• registering a User account;
• user authorization in the Operator’s services;
• provision of services for booking, hotel registration, identity confirmation, ordering goods to the room and providing hotel services;
• improving the quality of the Service provided by the operator;
• to prevent potentially prohibited and illegal activities;
• to answer any questions the User may have.

5.2. The Operator has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive information messages by sending the Operator an email to support@wroomify.ru with the note “Refusal of notifications about new products and services and special offers.”
5.3. Anonymized data of Users, collected using Internet statistics services, serves to collect information about the actions of Users on the site, improve the quality of the site and its content.
5.4. The Operator uses Yandex Metrica to collect data about User's actions on services.

6. Composition of personal data
6.1. The personal data of Users for the purpose of processing personal data specified in clause 5.1 and clause 5.2. includes:

• Full Name;
• Email address;
• Phone number;
• Information about the date, time, place of provision of services;
• Information about third parties (last name, first name, patronymic, phone number, email) provided by the User;
• Data on delivery addresses of orders;
• Copies of identification documents (of the User and a third party), as well as other documents provided by the User and containing personal data;
• Photo (portrait) of the User at the time of using the Terminal through photo/video recording;
• Photo (portrait) of a Third Party at the time of using the Terminal through photo/video recording;
• Data of banking products (credit, debit cards);
• Data on payments for orders and related services;
• Electronic correspondence.

7. Collection and processing of personal data
7.1. The User provides the Operator with reliable information about themselves.
7.2. The User provides the Operator with reliable information about third parties, if this is provided for by the functionality of the Services, as well as in the case where the User has received permission to transfer personal data of a third party.
7.3. The User provides consent to the processing of personal data to the Operator immediately at the time of registration, using a special field in which the User confirms that he has read and accepted the terms of this Personal Data Processing Policy.
7.4. Consent to the processing of personal data is valid for the entire duration of this Policy.
7.5. When using the site, anonymized data about visitors (including cookies) is collected using Internet statistics services (Yandex. Metrica, Google Analytics and others).
7.6. The Processing of special categories of Personal Data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.
7.7. The processing of personal data is carried out on a legal and fair basis.
7.8. The processing of personal data is limited to the achievement of specific, pre-defined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
7.9. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
7.10. The content and volume of personal data processed correspond to the stated purposes of processing. Redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
7.11. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
7.12. Only the Operator’s employees who are authorized to work with the User’s personal data and have signed a Non-Disclosure Agreement for the User’s personal data may have access to the processing of the User’s personal data.

8. Legal grounds for processing personal data
8.1. The legal grounds for the processing of personal data by the Operator are:

• statutory documents of the Operator;
• agreements concluded between the operator and the User;
• federal laws, other regulations in the field of personal data protection;
• the User's consent to the processing of their personal data, to the processing of personal data permitted for distribution.

8.2. The Operator processes the User’s personal data only if it is filled out and/or sent by the User independently through special forms located in the Wroomify services. By filling out the appropriate forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (saving cookies and using JavaScript technology are enabled).
8.4. The User independently decides to provide their personal data or personal data of third parties, if this is provided for by the functionality of the services, and the User has received an agreement from third parties, and gives consent freely, of their own free will and in their own interest.

9. Conditions for processing personal data
9.1. The User confirms that checking the “I have read and accept the terms of the user agreement and privacy policy” checkbox means full agreement with all the provisions of this Policy of them and third parties associated with the User through the Booking.
9.2. The Operator does not verify the accuracy of the personal data provided by the User. The Operator assumes that the User provides reliable and sufficient information about themselves and a third party, if provided for by the functionality of the services, and keeps it up to date.
9.3. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or law, to implement the functions, powers and responsibilities assigned by the legislation of the Russian Federation to the operator.
9.4. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.5. Processing of personal data is necessary for the execution of an agreement to which the User is a party or beneficiary or guarantor, as well as to conclude an agreement at the initiative of the User or an agreement under which the User will be a beneficiary or guarantor.
9.6. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the User are not violated.

10. The procedure for storing, transferring and other types of processing of personal data
10.1. The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
10.2. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
10.3. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or in the event that the User has given consent to the Operator to transfer data to a third party to fulfill obligations.
10.4. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator to the Operator's e-mail address support@wroomify.ru marked “Updating personal data.” The Operator's response time is 10 days.
10.5. If the User wishes to delete his data from the Operator’s services, he is obliged to send a notification to the Operator to the Operator’s email address support@wroomify.ru with the note “Deletion of personal data.” The operator's response time is 10 days.
10.6. The Operator stores personal data of Users on the territory of the Russian Federation in the ways provided for by the Law on Personal Data.
10.7. The protection of the User's personal data is carried out at the expense of the Operator in the manner established by the Federal Law of the Russian Federation.
10.8. When protecting Users’ personal data, the operator takes the necessary technical, legal, organizational and administrative measures:

• antivirus protection;
• intrusion detection and prevention;
• access control;
• encryption tools;
• internal acts regulating the protection of personal data.

10.9. The following have access to the User’s personal data and the ability to process them:

• employees of the Operator who need personal data in connection with the performance of their job duties;
• bodies of the Federal Migration Service.

10.10. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by the 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 support@wroomify.ru marked “Withdrawal of consent to the processing of personal data.” The Operator's response time is 10 days.
10.11. All information that is collected by third-party services, including payment systems, communications and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently familiarize himself with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.
10.12. The prohibitions established by the User on the transfer (except for providing access to services), as well as on the processing or conditions for processing (except for gaining access to services) of personal data, do not apply in cases of processing personal data in the state interests determined by the legislation of the Russian Federation.
10.13. When processing personal data, the Operator ensures the confidentiality of personal data.
10.14. The Operator stores personal data in a form that allows identifying the subject of personal data for no longer than required by the purposes of processing personal data, unlessthe period for storing personal data is not established by federal law, an agreement to which the subject of the personal data is a party, beneficiary or guarantor.
10.15. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the User’s consent or the withdrawal of consent by the User, as well as the identification of unlawful processing of personal data.

11. List of actions performed by the Operator with received personal data
11.1. The Operator collects, records, systematizes, accumulates, stores, refines (updates, changes), extracts, uses, transfers (distribute, provide, access), depersonalizes, blocks, deletes and destroys personal data.
11.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

12. Cross-border transfer of personal data
12.1. Before the start of cross-border transfer of personal data, the Operator is obliged to make sure that the foreign state into whose territory it is intended to transfer personal data provides reliable protection of the User’s rights.
12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements can only be carried out if there is written consent from the User to the cross-border transfer of their personal data and/or execution of an agreement to which the User is a party.

13. Confidentiality of personal data
13.1. The Operator and other persons who have access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the User, unless otherwise provided by federal law.

14. Final provisions

14.1. The User can receive any clarification on issues of interest regarding the processing of their personal data by contacting the Operator via email support@wroomify.ru

14.2. This document will reflect any changes to the Operator’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.

14.3. The current version of the Policy is freely available on the Internet at https://wroomify.ru/privacy_policy_en, in the Wroomify web application and in the Wroomify guest registration terminal.