Personal Data Processing Policy1. General Provisions

This Personal Data Processing Policy is drafted in accordance with the requirements of the Federal Law of July 27, 2006, No. 152-FZ "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 taken by Globaris Estate (hereinafter referred to as the "Operator"). 1.1. The Operator's primary goal and condition for its activities is to respect human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy, personal, and family secrets. 1.2. This Operator's Policy regarding 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://title-coralina-phuket.com/en.


2. Key Concepts Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology. 2.2. Blocking of personal data – temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data). 2.3. Website – a collection of graphic and information materials, as well as computer programs and databases ensuring their availability on the Internet at the address https://title-coralina-phuket.com/en. 2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means ensuring their processing. 2.5. Depersonalization of personal data – actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other data subject. 2.6. Processing of personal data – any action (operation) or set of actions performed with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction. 2.7. Operator – a state body, municipal body, legal entity, or individual organizing and/or performing the processing of personal data, as well as determining the purposes, composition, and actions performed with personal data. 2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://title-coralina-phuket.com/en. 2.9. Personal data permitted for distribution – personal data to which access is provided to an unlimited number of persons by the data subject through consent in the manner prescribed by the Personal Data Law. 2.10. User – any visitor to the website https://title-coralina-phuket.com/en. 2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or circle of persons. 2.12. Distribution of personal data – actions aimed at disclosing personal data to an undefined circle of persons, including publication in the media or information networks. 2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign authority, individual, or legal entity. 2.14. Destruction of personal data – actions resulting in the irrevocable destruction of personal data with no possibility of restoration.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to: — Receive accurate information and documents containing personal data from the subject; — Continue processing without consent if grounds specified in the Personal Data Law exist after a withdrawal of consent; — Independently determine the necessary and sufficient measures to ensure compliance with the Law. 3.2. The Operator is obliged to: — Provide the subject with information regarding their data processing upon request; — Organize processing in accordance with the current legislation of the Russian Federation; — Respond to requests from subjects or their legal representatives; — Notify the authorized body (Roskomnadzor) within 10 days of a request; — Publish or provide unrestricted access to this Policy; — Implement legal, technical, and organizational measures to protect data.
4. Basic Rights and Obligations of Data Subjects
4.1. Data subjects have the right to: — Receive information regarding the processing of their data; — Demand clarification, blocking, or destruction of incomplete, outdated, or inaccurate data; — Withdraw consent at any time; — Appeal against unlawful actions or omissions of the Operator to the authorized body or court. 4.2. Data subjects are obliged to: — Provide the Operator with accurate personal data; — Inform the Operator about updates or changes to their data.
5. Principles of Personal Data Processing
  • Processing is carried out on a legal and fair basis.
  • Processing is limited to achieving specific, predetermined, and legitimate goals.
  • Databases containing data processed for incompatible purposes shall not be merged.
  • Data must be accurate, sufficient, and relevant to the purposes of processing.
6. Purposes of Personal Data Processing
  • Purpose of processing: Providing information.
  • Personal data: Surname, first name, patronymic; phone numbers.
  • Legal grounds: Statutory (constituent) documents of the Operator.
  • Types of processing: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
7. Conditions for Processing
Processing is carried out with the subject's consent, or if necessary for the performance of a contract, the administration of justice, or to achieve goals provided for by international treaties or law.
8. Procedure for Collection, Storage, and Transfer
8.1. The Operator ensures safety and excludes unauthorized access. 8.2. Data will never be transferred to third parties except for legal compliance or performance of a contract. 8.3. Inaccuracies: Users can update data by emailing info@title-coralina-phuket.com with the subject "Personal Data Update." 8.4. Withdrawal: Consent can be withdrawn at any time by emailing info@title-coralina-phuket.com with the subject "Withdrawal of consent." 8.5. Third-party services: Information collected by third-party services (e.g., payment systems) is processed according to their own privacy policies.
9. Operator's Actions
The Operator performs collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, depersonalization, blocking, deletion, and destruction.
10. Cross-border Transfer
10.1. Before commencing cross-border transfer, the Operator must notify the authorized body of its intention. 10.2. Before notification, the Operator must obtain necessary information from the foreign authorities or entities.
11. Confidentiality
The Operator and persons with access to data are obliged not to disclose it to third parties without consent, unless otherwise provided by federal law.
12. Final Provisions
12.1. Users can receive clarifications by contacting the Operator via email at info@title-coralina-phuket.com. 12.2. This document will reflect any changes to the Policy. It is valid indefinitely until replaced by a new version. 12.3. The current version of the Policy is freely available at: https://title-coralina-phuket.com/en/privacy-policy.
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