1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data” (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and measures to ensure the security of personal data, undertaken by Individual Entrepreneur Dmitry Vladimirovich Maksimov (hereinafter referred to as the "Operator").
1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the right to privacy, personal and family secrecy, to be the most important goal and condition for its activities.
1.2. This Operator’s Policy on the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may receive about visitors to the website https://walkswithfolks.com.

2. Key Definitions Used in the Policy

2.1. Automated processing of personal data — processing using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and information materials, as well as software and databases, that ensure their availability on the Internet at https://walkswithfolks.com.
2.4. Personal Data Information System — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions resulting in the impossibility of determining the data’s belonging to a specific User or another personal data subject without using additional information.
2.6. Processing of personal data — any operation or set of operations performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.
2.7. Operator — a government body, municipal authority, legal or natural person, independently or together with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes and scope of the personal data to be processed, and the actions performed with the data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://walkswithfolks.com.
2.9. Personal data allowed for distribution by the subject — personal data to which the subject has given access to an unlimited number of people by giving consent in the manner prescribed by the Personal Data Law.
2.10. User — any visitor to the website https://walkswithfolks.com.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group.
2.12. Distribution of personal data — any actions aimed at disclosing data to an indefinite number of people, including publication in mass media, placement in information and communication networks, or providing access in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign government body, foreign individual, or foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of data with no possibility of restoration, including destruction of physical media.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

• receive from the personal data subject accurate information and/or documents containing personal data;
• in the event that the personal data subject withdraws their consent to the processing of personal data, or submits a request to stop processing, the Operator has the right to continue processing the data without the subject’s consent if there are legal grounds provided for in the Personal Data Law;
• independently determine the list and scope of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise specified by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

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

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

• receive information regarding the processing of their personal data, except in cases provided by federal laws. The information must be provided by the Operator in an accessible form and must not include personal data relating to other subjects, unless there are legal grounds for disclosing such data. The list of such information and the procedure for obtaining it are established by the Personal Data Law;
• request the Operator to clarify, block, or delete their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
• impose a condition of prior consent for the processing of their personal data for the purposes of marketing goods, works, and services;
• withdraw consent to the processing of their personal data and submit a demand to stop its processing;
• appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or inaction of the Operator in processing their personal data;
• exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the Operator with accurate information about themselves;
• inform the Operator of clarifications (updates or changes) to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-defined, and lawful purposes. Processing of personal data that is incompatible with the purposes of data collection is not permitted.
5.3. The combination of databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other, is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and scope of processed personal data must correspond to the stated purposes of processing. The processing of excessive personal data in relation to the declared purposes is not permitted.
5.6. During the processing of personal data, the accuracy, sufficiency, and, where necessary, the relevance of the data in relation to the purposes of processing must be ensured. The Operator shall take necessary measures and/or ensure their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows identifying the subject of personal data no longer than required for the purposes of processing, unless a different storage period is established by federal law or a contract to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achieving the purposes of processing or if the need to achieve these purposes is lost, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

6.1. Purpose of processing: Handling tour bookings and responding to inquiries.
6.2. Personal data:

• Surname, first name, patronymic
• Email address
• Phone numbers
• Details related to the tour booking, including dates, number of participants, and any special requirements

6.3. Legal basis:
Federal Law "On Information, Information Technologies and Information Protection" dated 27.07.2006 No. 149-FZ
6.4. Types of personal data processing:
Transfer of personal data

7. Conditions for Processing Personal Data

7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary for achieving the purposes provided for by an international treaty of the Russian Federation or by law, and for the performance of functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, enforcement of a judicial act, or an act of another authority or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract under which the subject will be the beneficiary or guarantor.
7.5. The processing of personal data is necessary for the realization of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the personal data subject are not violated.
7.6. The processing of personal data is carried out in cases where the data has been made publicly accessible by the personal data subject or at their request (hereinafter referred to as “public personal data”).
7.7. The processing of personal data is carried out when such data is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.
8.1. The Operator ensures the confidentiality of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases required by applicable law or when the personal data subject has given consent to the Operator for the transfer of data to a third party in order to fulfill obligations under a civil contract.
8.3. If inaccuracies in personal data are identified, the User may update them independently by sending a notification to the Operator’s email address at info@walkswithfolks.com with the subject line “Personal Data Update”.
8.4. The duration of personal data processing is determined by the achievement of the purposes for which the data was collected, unless a different period is specified by contract or applicable law.
The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email at info@walkswithfolks.com with the subject line “Withdrawal of Consent to 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 those parties (Operators) in accordance with their own Terms of Use and Privacy Policies. The personal data subject is responsible for familiarizing themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. Any restrictions imposed by the personal data subject on the transfer (except for granting access) or on the processing or conditions of processing (except for access) of personal data intended for public distribution do not apply in cases where such data is processed in the public interest as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identifying the personal data subject no longer than required for the purposes of processing, unless a longer retention period is provided by federal law or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. Grounds for terminating the processing of personal data may include the achievement of the processing purposes, the expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, a demand to stop processing, or the discovery of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Collected Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with or without the receipt and/or transfer of the obtained information via information and telecommunication networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing the cross-border transfer of personal data, the Operator is required to notify the authorized body responsible for the protection of the rights of personal data subjects of its intention to carry out such a transfer (this notification is submitted separately from the general notification on the intention to process personal data).
10.2. Prior to submitting the above-mentioned notification, the Operator must obtain relevant information from the governmental authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and any other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties 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 questions related to the processing of their personal data by contacting the Operator via email at info@walkswithfolks.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at: https://walkswithfolks.com/ru/privacy-policy.