Авиакомпания АЛРОСА - Главная страница
Баннер оглавления
Privacy policy

Privacy policy

Security

Policy of JSC ALROSA Airlines regarding the processing of personal data

General Provisions

The policy of JSC "ALROSA Airlines" regarding the processing of personal data (hereinafter referred to as the Policy) is the fundamental document that declares the principles of JSC "ALROSA Airlines" activities in the processing and protection of personal data (hereinafter also referred to as PD) in the presence of security threats relevant to the processing of PD.

The principles and rules for protecting individuals when processing their personal data, regardless of citizenship or place of residence, must comply with fundamental rights and freedoms, in particular, the right to the protection of personal data.

JSC "ALROSA Airlines" considers it a priority to ensure the safety of its clients, including information and any other security.

JSC "ALROSA Airlines" aims to ensure the protection of the rights and freedoms of individuals and citizens and guarantees a high level of protection of personal data of existing and potential clients, website users, mobile site users, and other individuals whose personal data it processes.

JSC "ALROSA Airlines" determines the purposes and methods of processing personal data within the framework of the Policy, controls and processes personal data, acting as a "personal data operator" and operates in accordance with the current legislation.

The location of the personal data operator: JSC "ALROSA Airlines" 678174, Russian Federation, Republic of Sakha (Yakutia), Mirninsky municipal district, urban settlement of Mirny, Mirny city, Almaznikov highway, building 5/1, 2nd floor. This policy is developed in accordance with the requirements of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data", as well as taking into account the Recommendations for the preparation of a document defining the operator's policy regarding the processing of personal data, in the manner established by the Federal Law of July 27, 2006 N 152-FZ "On Personal Data".

The Policy uses terms and definitions in accordance with the Federal Law of 27.07.2006 N 152-FZ "On Personal Data", as well as the following definition.

The legal grounds for the processing of PD in JSC "ALROSA Airlines" are local regulatory acts governing the processing of personal data, other regulatory and other acts of JSC "ALROSA Airlines" in this area.

Principles for processing personal data

JSC "ALROSA Airlines" establishes the following principles:

  • Personal data is processed in accordance with the law, transparently and impartially.

  • Personal data is processed for clearly defined, specific purposes and will not be processed in any way that contradicts these purposes and the law.

  • Personal data is processed only to the extent necessary for the stated purposes.

  • All feasible and possible measures are taken to ensure accurate and up-to-date personal data, as well as reasonable measures to ensure the timely deletion or correction of inaccurate data, taking into account the purposes for which they are processed.

  • Personal data is stored in a form that allows the identification of data subjects for the period necessary for the purposes for which personal data is processed; personal data may be stored for a longer period if it will be processed solely for purposes of public interest, as well as for scientific or historical research, or for statistical purposes.

  • Personal data is processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical and organizational measures.

Purposes of processing personal data

JSC "ALROSA Airlines" processes personal data for the following purposes:

  • Fulfillment of obligations in the provision of services, including air transportation or other services, regardless of whether such services are provided by JSC "ALROSA Airlines" or intermediaries on behalf of JSC "ALROSA Airlines";

  • Managing the boarding process and connecting flights during transfer transportation;

  • Ensuring safety on JSC "ALROSA Airlines" flights and complying with existing legal and regulatory requirements applicable to the activities of JSC "ALROSA Airlines";

  • Providing special services and ensuring a personalized approach;

  • Conducting market research.

  • Conducting marketing campaigns and informing clients about the products and services of JSC "ALROSA Airlines" and its partners;

  • Conducting targeted advertising;

  • Ensuring the sending of messages about flight status, etc.;

  • Improving the website, mobile site, products, and services;

  • Implementing the "Diamond Mile" Loyalty Program;

  • Performing other functions in the course of activities and providing services to consumers.

Methods of processing personal data.

JSC "ALROSA Airlines" keeps records of all activities related to the processing of personal data. Personal data is processed both manually and using automation tools by collecting, recording, systematizing, accumulating, storing, clarifying (updating, modifying), extracting, using, transferring (providing, granting access), anonymizing, blocking, deleting, destroying personal data in accordance with legal requirements.

The processing of personal data is carried out with the consent of the subject of personal data for the processing of their personal data, unless otherwise provided by the legislation of the Russian Federation in the field of personal data.

JSC "ALROSA Airlines" does not disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by the legislation of the Russian Federation and/or the terms of the Policy.

JSC "ALROSA Airlines" has the right to entrust the processing of personal data to another person with the consent of the subject of personal data based on a contract concluded with this person.

Methods for obtaining personal data

  • Conclusion of a contract with JSC "ALROSA Airline";

  • The use by a client or potential client of the website of JSC "ALROSA Airline", the mobile application, making calls to the contact center of JSC "ALROSA Airline", or sending messages via email;

  • Receiving information from partner organizations, including companies engaged in organizing the client's travel, airlines servicing previous or subsequent flights, relevant airport services, customs and immigration services;

  • Receiving information from companies participating in loyalty programs and other customer programs.

Volume and categories of personal data processed, categories of personal data subjects.

The volume of processed personal data corresponds to the goals of PD processing established by the Policy. JSC "ALROSA Airline" guarantees that the processed PD will not be excessive in relation to the declared goals of their processing.

    The category of processed PD includes:

  • Information provided to JSC "ALROSA Airline" for completing bookings and managing them, as well as providing a range of other related services. This includes name, address, email address, contact details, date of birth, gender, passport number, account data, and payment information, for both the passenger and the customer, if they are different persons;

  • Information about the person making the sale, such as a travel agency or website;

  • Information about the details of the trip, including flights – booking data, itinerary, information on necessary additional services, and other information;

  • Information about previously provided services;

  • Information about online check-in and other forms of interaction;

  • Information about website usage, host IP address, user browser, its location, contact centers, and mobile applications.

    The category of PD subjects includes:

  • Employees of JSC "ALROSA Airline", candidates for vacant positions, and former employees;

  • PD subjects related to the employees of JSC "ALROSA Airline";

  • Clients and contractors of JSC "ALROSA Airline", including individuals;

  • Other PD subjects whose data is processed in the course of achieving the goals specified in section 3 of the Policy.

Processing of special categories of personal data

Some categories of personal data, such as racial or ethnic origin, religious beliefs, political opinions, health status, sexual orientation, biometric, and genetic information, are considered special categories of data that require additional protection. JSC "ALROSA Airline" limits the cases in which special personal data is processed. JSC "ALROSA Airline" is required to process special personal data under certain circumstances, such as:

  • When providing special medical conditions for flying;

  • When receiving biometric information (for example, facial recognition) during security checks before and after traveling on flights operated by JSC "ALROSA Airline".

Additionally, a client may request services (such as meals) that are not related to special data but may indicate religious beliefs, health conditions, or other information.

Consent to the processing of personal data

JSC "ALROSA Airline" processes the personal data of its clients and potential clients with their consent and in cases provided for by law. Under certain circumstances, the collection and use of personal data is carried out solely with the consent of the client or potential client, including for marketing purposes, such as sending information about promotional campaigns conducted by JSC "ALROSA Airline" and its partners* as well as informational messages, the use of cookies (text files intended for identifying the user's computer), or processing special categories of personal data. Consent for the processing of personal data must be specific, informed, and conscious.

In the case of the incapacity of the personal data subject, consent for the processing of their personal data is provided by the legal representative of the personal data subject. Considering the available technological capabilities, JSC "ALROSA Airline" takes reasonable measures to confirm that consent was given by the legal representative of the incapacitated individual.

Consent for the processing of personal data can be revoked at any time. The revocation of consent for the processing of personal data can only be made for the future and cannot affect the legality of the processing of personal data that occurred prior to the revocation of consent. In the event that the consent is revoked by the personal data subject, JSC "ALROSA Airline" may partially or completely be unable to provide the client or potential client with the services requested.

In the event of a revocation of consent for the processing of personal data, JSC "ALROSA Airline" has the right to continue processing personal data without the consent of the client or potential client if there are grounds provided for by legislation.

Rights of the subject of personal data

  • The data subject has the right to request confirmation of whether their personal data is being processed, and upon confirmation, has the right to receive information concerning the processing of their personal data.

  • The data subject can declare the termination of the use of their personal data. This does not apply in cases where the use of data is required within the framework of judicial proceedings or there are other legal grounds for not ceasing the use of personal data.

  • The data subject can request changes to their inaccurate personal data. Considering the purposes of processing, the data subject has the right to make additions to their personal data, including by submitting additional statements.

  • The data subject has the right to request a restriction on the processing of their personal data.

  • The data subject has the right to require the immediate deletion of their personal data.

  • If personal data is processed for direct marketing purposes, the data subject has the right to object to the processing of their personal data for those marketing purposes.

  • The data subject has the right to appeal against the actions of the personal data operator.

Transfer of personal data

Data received on the website and in the mobile application of JSC "ALROSA Airline" may be transferred to authorized employees of JSC "ALROSA Airline", partner organizations (accredited agencies, other carriers, for example, if one or more flights are operated by other airlines, banking companies, LLC "ALROSA Business Service") and other service providers mentioned above. A similar situation arises when booking tickets for flights directly through JSC "ALROSA Airline" if one or more flights are operated by another carrier. In the event that the user navigates to external sites via external links, JSC "ALROSA Airline" is not responsible for the confidentiality of personal data. However, JSC "ALROSA Airline" requires all its partners to implement strict measures to ensure confidentiality and data protection.

In certain cases as stipulated by regulatory acts, JSC "ALROSA Airline" will be obliged to provide accounting information to supervisory authorities upon their request. For example, to fulfill mandatory formalities related to immigration, defense and security, including transportation security, counter-terrorism, and anti-corruption, etc.

Some of the aforementioned recipients of customers' personal data are located outside the territory of the Russian Federation, including in the EU, as well as in countries where an equally high level of personal data protection is not ensured. When such cross-border transfer of personal data occurs, JSC "ALROSA Airline", in accordance with applicable data protection legislation, seeks to ensure an adequate level of data protection. In the event that personal data is transferred to a foreign state, the procedure for processing personal data will be regulated by the legislation of the respective state.

Updating, correction, deletion and destruction of personal data

In the case of confirming the inaccuracy of personal data or the illegality of its processing, the personal data must be updated, and the processing should be stopped accordingly.

Upon achieving the purposes of processing personal data, as well as in the case of the revocation of consent to their processing by the personal data subject, the personal data must be destroyed if:

  • Otherwise provided for by a contract, of which the personal data subject is a party, a beneficiary, or a guarantor;

  • JSC "ALROSA Airline" has no right to process without the consent of the personal data subject on grounds provided by the legislation of the Russian Federation;

  • Nothing else is provided for in any other agreement between JSC "ALROSA Airline" and the personal data subject.

JSC "ALROSA Airline" is obliged to inform the personal data subject or their representative about the processing of their personal data at the request of the latter.

Changes in the policy of JSC ALROSA Airlines regarding the processing and protection of personal data

Changes to the Policy may occur in order to enhance the level of protection for personal data. In case of changes to the Policy, the updated version will be promptly published on the official website of JSC "ALROSA Airlines".

For inquiries regarding JSC "ALROSA Airlines" policies on the processing and protection of personal data, you may contact the data protection officer at the email address avia-info@aero.alrosa.ru. To withdraw consent for the processing of personal data, the client must send a written request containing a personal signature to JSC "ALROSA Airlines"; the request should be sent by postal mail to the address avia-info@aero.alrosa.ru. In the event of withdrawal of consent by the data subject, JSC "ALROSA Airlines" will be unable to provide the client or potential client with the services they requested, either partially or fully.