Issued on: 15.02.2024
The full version of the current document is available at: mosshospitality.ru/policy/en

1. The subject of the Privacy Polity

The present Privacy Policy (hereafter referred to as “Policy”) applies to any information, including personal data within the meaning of the applicable laws (hereafter referred to as “Personal data”) that MOSS HOSPITALITY OOO and/or its affiliates, including those belonging to the same group as MOSS HOSPITALITY OOO (hereafter referred to as the “Company”), may obtain about you in the course of your use of any websites, programmes, products, and/or services of the Company (hereafter collectively referred to as the “Services”) as described on mosshospitality.ru or on any other website owned by the Company (hereafter collectively referred to as the “Websites”) as well as in the course of performance of any agreements or contracts concluded with you by the Company in connection with your use of the Services. The Company may also obtain personal data from its partners (hereafter referred to as “Partners”), whose website, programmes, products or services you use, or from other sources where personal data is publicly available. Where applicable, the transfer of personal data is possible exclusively in line with the applicable legislation and is carried out on the basis of separate agreements between the Company and each of its Partners.


2. The Operator of the Privacy Policy

The personal data essential to your use of the Websites is collected and processed by MOSS Hospitality OOO (Limited Liability Company), a legal entity established under the laws of the Russian Federation and registered at the following address: Moscow 105082, Basmanny municipal district, Perevedenovsky pereulok 13, bld. 18, office 34H/52.


3. Objectives of the Privacy Policy

The protection of your personal data and privacy is paramount to the Company. Therefore, whenever you use the Websites and their services, the Company protects and processes your personal data in strict conformity with the applicable laws. The protection of human rights and liberties, including the rights to privacy as well as personal and family secrecy, is an important objective for the Company.

4. Details of personal data processed by the Company

During your use of the Websites, the Company may collect the following personal data:

(i) Personal information provided upon registration (when you create the account), such as your name, mobile number, address, and age;

(ii) digital data (HTTP headers, IP addresses, cookies, web-beacons / pixel tags, browser ID, hardware and software information, and wi-fi network data;

(iii) date and time of your access to the Websites;

(iv) information about your activities on the Websites (e.g. search history, purchase data, likes and preferences, and email addresses);

(v) geolocation;

(vi) any other personal information required in accordance with the terms and conditions of the Websites’ use;

(vii) details of your payment cards or any other payment forms provided by you or obtained from other persons involved financial transactions on the Websites or in connection with paid services provided by the Company;
The Company also uses cookies to collect personal data and associate it with your devices and web browsers. The Company does not deliberately collect sensitive personal information such as racial origin, political views, health details, or biometric data.
By personal data processing we mean any action, operation, or set of actions or operations performed with personal data with or without the use of computers, including its collection, recording, systematisation, accumulation, storage, update or change, extraction, use, transfer (including distribution, provision, or access), depersonalisation, blocking, deletion, or destruction.

5. Legal basis and purpose of personal data processing

The Company may not process your personal data without sufficient legal grounds. Therefore, the Company will only process your personal data if:

(i) such processing is necessary for the fulfilment of contractual obligations between yourself and the Company;

(ii) such processing is required to fulfil statutory obligations;

(iii) whenever required by the applicable law, such processing is necessary to accommodate the legitimate interests of the Company, provided that the processing has no significant impact on your interests, fundamental rights, and freedoms. Please note that while processing your personal data on this basis, the Company will endeavour to maintain a balance between its legitimate interests and the protection of your privacy.
The Company processes your personal information in its legitimate interests, for instance, in the following cases:
(a) to better understand the way you interact with the Websites and/or their Services;;
(b) to improve, change, personalise, or otherwise enhance the Websites and their Services for the benefit of all users;
(iv) for specific purposes or legal requirements, we may request a separate consent to process your personal data. We hereby inform you, and you acknowledge, that you are under no obligation to provide us with any personal data when you use the Websites or Services, and you do it on your own free will. However, you recognise that without your personal data we may not be able to provide you with Website Services and your use of the Websites may be restricted.
The Company always processes your personal data for specific purposes, using only the details relevant for these purposes. Notably, we process your personal data with the following goals:
(i) providing Websites access (including the search results responding to your search queries that are based on your preferences, search history, and other personal information);

(ii) providing access to your account, including your email and data storage;

(iii) communicating with you in order to send notices, requests, and information related to the functioning of the Websites, the correct fulfilment of agreements and the processing of your requests and applications;

(iv) personalising advertisements and special offers in line with your preferences, search history, and other personal details obtained by the Company;

(v) optimising the performance of the Websites and their Services as well as improving usability and the relevance of search results;

(vi) acceptance of your payments for goods at services acquired at the Websites.

6. Protection of your personal data

As a rule, your personal information is processed automatically, and the Company’s employees have no access to it. Wherever such access is required, it may be granted particularly to those employees that need it for their work-related tasks. In order to ensure confidentiality and protect your data, these employees are bound by internal policies and procedures pertaining to personal data. They must also follow the technical and organisational security protocols implemented for personal data protection.

The Company may also transfer your personal data to third parties in order to achieve the objectives specified in Section 5 of the present Policy.

These third parties may include:

(i) Partners, such as website and application owners, advertising networks and other partners that provide advertising services to the Company;
(ii) advertisers and other Partners who display personalised advertisements on the Websites or provide information services and consulting;

(iii) persons responsible for the identification of security threats to the Websites and their Services;

(iv) persons responsible for the acceptance of your payments and payment transactions on the Websites.

7. Storage and processing of your personal data

Your personal data will be stored within the Russian Federation. The Company shall record, systematise, accumulate, store, update, change, and retrieve the personal data of Russian citizens using databases located in the Russian Federation.

8. Duration of personal information storage

The Company will retain your personal data for as long as it is necessary to reach the declared objectives of its collection or to comply with legal and regulatory requirements.

9. Use of cookies and similar technologies

A cookie is a small piece of data that is received and processed by the device that you use to access the Websites. Cookies store and feed back to the Websites the information that enhances your Website experience and allows us to remember your preferences, such as your browser settings or your profile.

The Websites uses the following categories of cookies:

• necessary / technical cookies: these are required for the correct functioning of the Websites and their Services. Notably, they allow the Company to identify your hardware and software, including your browser;
• statistical / analytical cookies: these cookies allow us to recognise and count users and learn about their Website operations, including the pages visited and the content received;
• technical cookies, required to collect information about user interactions with the Websites, identify errors and test new features improving Website performance;
• functional cookies, required to provide certain functions to facilitate Website use, for instance by storing your preferences (such as language and geolocation);
• (third party) tracking / advertising cookies: these cookies collect information about users, traffic sources, pages visited and adverts displayed or led to the advertised page. They select advertisements that may be of interest on the basis of the analysis of the collected data. These cookies are also used for statistical and research purposes.

When you first visit the Websites, your consent to the use of cookies may be requested. If you wish to change your mind, you can do so by deleting the cookies stored on your browser. A pop-up window requesting your consent may then be displayed again and you will be able to make a different choice. If you refuse cookies, it may affect the use of certain features of the Websites or restrict the use of the Websites altogether.