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Personal Data Processing Policy
By filling out the form at https://insidersontour.com on the Internet, putting the “V” sign next to “I agree with the personal data processing policy and give my consent to the processing of my personal data” and clicking the “Submit” button, an individual confirms that he/she has read the terms of this personal data processing policy.
1. General Provisions
This document defines the policy of INSIDERS TOURS PTY) Ltd 2025/218636/07 (hereinafter referred to as the Operator) regarding the processing and confidentiality of personal data and information. The Policy also explains how the Operator processes and protects the personal data of subjects and other information of users.
The Policy governs the relationship between the Operator and any individual (client, client’s representative, users of the Websites and other persons specified in paragraph 3 of the Policy) regarding the processing of personal data of the said persons provided by them to the Operator.
The Policy applies to all Personal Data processing operations performed by the Operator, as well as to all information that the Operator and/or other authorized persons acting on behalf of the Operator may receive about the User during their use of any of the Operator's Products.
The Policy is mandatory for review and execution by all persons acting on behalf of the Operator, authorized to process personal data, and persons involved in organizing the processes of processing and ensuring the security of personal data.
2. Basic terms
Personal data (PD) — any information related to a directly or indirectly determined or determinable individual (personal data subject);
Personal data operator (operator) — a person who, alone or jointly with other persons, organizes and (or) carries out the processing of personal data, and determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data;
Processing of personal data — any action (operation) or set of actions (operations) with personal data, performed with or without the use of automation tools.
Automated processing of personal data — processing of personal data using computer technology;
Website — a collection of graphic and information materials, as well as computer programs and databases that make them available on the Internet at the network address: https://insidersontour.com/
Dissemination of personal data — actions aimed at disclosing personal data to an indefinite number of persons;
Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific number of persons;
Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which tangible media of personal data are destroyed;
Anonymization of personal data — actions as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information;
Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing;
Cross-border transfer of personal data is the transfer of personal data to a foreign government agency, foreign individual, or foreign legal entity.
Processors are individuals who have been instructed by the Operator to process Personal Data.
3. Processing of Personal Data by the Operator
3.1. Purposes, Legal Grounds, and Terms of Processing Personal Data.
The Operator processes Personal Data for the following purposes:
*When specifying the category of subject "Counterparty," this refers to clients and partners, unless otherwise specified.
By filling out the form at https://insidersontour.com on the Internet, putting the “V” sign next to “I agree with the personal data processing policy and give my consent to the processing of my personal data” and clicking the “Submit” button, an individual confirms that he/she has read the terms of this personal data processing policy.
1. General Provisions
This document defines the policy of INSIDERS TOURS PTY) Ltd 2025/218636/07 (hereinafter referred to as the Operator) regarding the processing and confidentiality of personal data and information. The Policy also explains how the Operator processes and protects the personal data of subjects and other information of users.
The Policy governs the relationship between the Operator and any individual (client, client’s representative, users of the Websites and other persons specified in paragraph 3 of the Policy) regarding the processing of personal data of the said persons provided by them to the Operator.
The Policy applies to all Personal Data processing operations performed by the Operator, as well as to all information that the Operator and/or other authorized persons acting on behalf of the Operator may receive about the User during their use of any of the Operator's Products.
The Policy is mandatory for review and execution by all persons acting on behalf of the Operator, authorized to process personal data, and persons involved in organizing the processes of processing and ensuring the security of personal data.
2. Basic terms
Personal data (PD) — any information related to a directly or indirectly determined or determinable individual (personal data subject);
Personal data operator (operator) — a person who, alone or jointly with other persons, organizes and (or) carries out the processing of personal data, and determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data;
Processing of personal data — any action (operation) or set of actions (operations) with personal data, performed with or without the use of automation tools.
Automated processing of personal data — processing of personal data using computer technology;
Website — a collection of graphic and information materials, as well as computer programs and databases that make them available on the Internet at the network address: https://insidersontour.com/
Dissemination of personal data — actions aimed at disclosing personal data to an indefinite number of persons;
Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific number of persons;
Destruction of personal data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which tangible media of personal data are destroyed;
Anonymization of personal data — actions as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information;
Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing;
Cross-border transfer of personal data is the transfer of personal data to a foreign government agency, foreign individual, or foreign legal entity.
Processors are individuals who have been instructed by the Operator to process Personal Data.
3. Processing of Personal Data by the Operator
3.1. Purposes, Legal Grounds, and Terms of Processing Personal Data.
The Operator processes Personal Data for the following purposes:
*When specifying the category of subject "Counterparty," this refers to clients and partners, unless otherwise specified.
3.1.1. The Operator does not process biometric Personal Data.
3.1.2. The Operator does not intentionally process the personal data of minors. The Contractor recommends that only persons aged 18 years or older use the Website. Responsibility for the actions of minors, including the purchase of services on the Website, lies with the legal representatives of the minors. All visitors under 18 years of age are required to obtain permission from their legal representatives before providing any personal information about themselves.
If the Operator becomes aware that it has received personal information about a minor without the consent of the legal representatives, such information will be deleted as soon as possible.
3.1.3. The terms for processing personal data are determined taking into account:
(1) the established purposes of processing personal data;
(2) the duration of agreements with personal data subjects and/or consents of personal data subjects to the processing of their personal data;
(3) the terms specified by the regulatory legal acts of the Russian Federation.
3.2. Principles and Conditions for Processing Personal Data by the Operator
3.2.1. The Operator processes Personal Data in a lawful and fair manner.
3.2.2. When processing Personal Data, its accuracy, sufficiency, and relevance in relation to the purposes of processing the Personal Data are ensured.
3.2.3. The Operator processes Personal Data with and without the use of automation tools. In doing so, the Operator complies with the requirements for automated and non-automated processing of personal data stipulated by the Law and regulatory legal acts adopted in accordance with it.
3.2.4. The Operator entrusts the Processing of Personal Data to other persons. In doing so, the Operator complies with all the requirements for entrusting the processing of personal data stipulated by the Law.
3.2.4.1. For the purpose of executing the agreement and registering a personal account on the TILDA PUBLISHING Platform, the Operator entrusts the processing of Personal Data to a personal data processor.
Processor on behalf of: Limited Liability Company "TILDA PUBLISHING" (TIN 7722391042; KPP 770201001; OGRN 1177746176211). Legal address: Moscow, Meshchansky District Municipal Okrug, Kuznetsky Most St., 19, building 1, floor / room 2/I, off. 28, E-mail: MTA2606@MAIL.RU
3.2.4.4. In order to build relationships with clients in the universal AmoCRM system, the Operator entrusts the processing of Personal data to the personal data processor.
Processor on behalf of: Joint-Stock Company "amoCRM" (TIN: 7709477879; OGRN: 5157746087681; KPP: 773101001). Legal address: 121205, Moscow, territory of the Skolkovo Innovation Center, Bolshoy Boulevard, 42, building 1, floor 4, room 1448, office 6, tel.: Contacts: 8 (800) 555-7364, +7 (495) 134-4564; E-mail: support@amocrm.ru.
3.2.4.5. For the purpose of exchanging text and multimedia messages using the Unisender SMART program, the Operator entrusts the processing of Personal data to the personal data processor.
Processor on behalf of: Unisender SMART LLC (TIN: 9731091240/771501001; OGRN: 1227700213180). Legal/Actual address: 127015, Moscow, internal territory of the city. Butyrsky Municipal District, Bolshaya Novodmitrovskaya St., Bldg. 23, e/premises 2/46.
3.2.5. The Operator shall not disclose to third parties or distribute Personal Data, except in the following cases:
(1) The Personal Data Subject has expressed their consent to such disclosure in advance.
(2) The transfer is necessary for the performance of an agreement to which the Personal Data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement on the initiative of the Personal Data subject or an agreement under which he will be a beneficiary or guarantor.
(3) The transfer is necessary to protect the rights and legitimate interests of the Operator or third parties;
(4) The transfer is initiated by the subject of the Personal data.
(5) The transfer 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 or other cases stipulated by the current legislation of the Russian Federation.
3.3. Conditions and restrictions on the processing of personal data permitted by the subject for distribution
3.3.1. The Operator, based on a separate consent of the subject of Personal data, processes certain categories of Personal data permitted by the subject for distribution and provision of access to an unlimited number of persons by posting them on the Websites with the domain and/or subdomain https://insidersontour.com , including in presentations, articles; in photos, audio and other works; in advertising on the Internet; in social networks - in official groups or accounts.
3.3.2. Personal data are posted for the purpose of (1) increasing the loyalty of users of the Websites and products of the Operator; (2) developing a positive attitude of users towards the Operator's products; (3) promoting the Operator's products, (4) as well as any goods, works and services related to the said products.
3.3.3. List of personal data and the presence/absence of restrictions or prohibitions in relation to them:
3.1.2. The Operator does not intentionally process the personal data of minors. The Contractor recommends that only persons aged 18 years or older use the Website. Responsibility for the actions of minors, including the purchase of services on the Website, lies with the legal representatives of the minors. All visitors under 18 years of age are required to obtain permission from their legal representatives before providing any personal information about themselves.
If the Operator becomes aware that it has received personal information about a minor without the consent of the legal representatives, such information will be deleted as soon as possible.
3.1.3. The terms for processing personal data are determined taking into account:
(1) the established purposes of processing personal data;
(2) the duration of agreements with personal data subjects and/or consents of personal data subjects to the processing of their personal data;
(3) the terms specified by the regulatory legal acts of the Russian Federation.
3.2. Principles and Conditions for Processing Personal Data by the Operator
3.2.1. The Operator processes Personal Data in a lawful and fair manner.
3.2.2. When processing Personal Data, its accuracy, sufficiency, and relevance in relation to the purposes of processing the Personal Data are ensured.
3.2.3. The Operator processes Personal Data with and without the use of automation tools. In doing so, the Operator complies with the requirements for automated and non-automated processing of personal data stipulated by the Law and regulatory legal acts adopted in accordance with it.
3.2.4. The Operator entrusts the Processing of Personal Data to other persons. In doing so, the Operator complies with all the requirements for entrusting the processing of personal data stipulated by the Law.
3.2.4.1. For the purpose of executing the agreement and registering a personal account on the TILDA PUBLISHING Platform, the Operator entrusts the processing of Personal Data to a personal data processor.
Processor on behalf of: Limited Liability Company "TILDA PUBLISHING" (TIN 7722391042; KPP 770201001; OGRN 1177746176211). Legal address: Moscow, Meshchansky District Municipal Okrug, Kuznetsky Most St., 19, building 1, floor / room 2/I, off. 28, E-mail: MTA2606@MAIL.RU
3.2.4.4. In order to build relationships with clients in the universal AmoCRM system, the Operator entrusts the processing of Personal data to the personal data processor.
Processor on behalf of: Joint-Stock Company "amoCRM" (TIN: 7709477879; OGRN: 5157746087681; KPP: 773101001). Legal address: 121205, Moscow, territory of the Skolkovo Innovation Center, Bolshoy Boulevard, 42, building 1, floor 4, room 1448, office 6, tel.: Contacts: 8 (800) 555-7364, +7 (495) 134-4564; E-mail: support@amocrm.ru.
3.2.4.5. For the purpose of exchanging text and multimedia messages using the Unisender SMART program, the Operator entrusts the processing of Personal data to the personal data processor.
Processor on behalf of: Unisender SMART LLC (TIN: 9731091240/771501001; OGRN: 1227700213180). Legal/Actual address: 127015, Moscow, internal territory of the city. Butyrsky Municipal District, Bolshaya Novodmitrovskaya St., Bldg. 23, e/premises 2/46.
3.2.5. The Operator shall not disclose to third parties or distribute Personal Data, except in the following cases:
(1) The Personal Data Subject has expressed their consent to such disclosure in advance.
(2) The transfer is necessary for the performance of an agreement to which the Personal Data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement on the initiative of the Personal Data subject or an agreement under which he will be a beneficiary or guarantor.
(3) The transfer is necessary to protect the rights and legitimate interests of the Operator or third parties;
(4) The transfer is initiated by the subject of the Personal data.
(5) The transfer 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 or other cases stipulated by the current legislation of the Russian Federation.
3.3. Conditions and restrictions on the processing of personal data permitted by the subject for distribution
3.3.1. The Operator, based on a separate consent of the subject of Personal data, processes certain categories of Personal data permitted by the subject for distribution and provision of access to an unlimited number of persons by posting them on the Websites with the domain and/or subdomain https://insidersontour.com , including in presentations, articles; in photos, audio and other works; in advertising on the Internet; in social networks - in official groups or accounts.
3.3.2. Personal data are posted for the purpose of (1) increasing the loyalty of users of the Websites and products of the Operator; (2) developing a positive attitude of users towards the Operator's products; (3) promoting the Operator's products, (4) as well as any goods, works and services related to the said products.
3.3.3. List of personal data and the presence/absence of restrictions or prohibitions in relation to them: