Personal Data Processing Policy of ООО УК «КАПО-Жилбытсервис»
Last updated: 12 September 2026
1. General provisions
1.1. This Personal Data Processing Policy (the “Policy”) has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (“Law No. 152-FZ”). It sets out how ООО УК «КАПО-Жилбытсервис» (the “Operator”) processes and protects personal data collected through the official website of Aviator Hotel, gosaviator.ru, and in the provision of hotel services.
1.2. The Policy is publicly available at gosaviator.ru without registration or downloading.
1.3. Terms used in this Policy have the meanings given in Article 3 of Law No. 152-FZ.
2. Information about the Operator
| Item | Details |
|---|---|
| Name | ООО УК «КАПО-Жилбытсервис» |
| OGRN (Primary State Registration Number) | 1081690080450 |
| INN (Taxpayer Identification Number) | 1661022862 |
| Registered address | 9 Akademika Pavlova Street, Kazan, Republic of Tatarstan 420127, Russia |
| Hotel address | 1 Akademika Pavlova Street, Kazan, Republic of Tatarstan 420127, Russia |
| Telephone | +7 (843) 204-99-01, +7 (843) 204-99-02, +7 (937) 615-40-12 |
| gos-aviator@yandex.ru; 5719901@bk.ru | |
| Website | gosaviator.ru |
| Accommodation category | Three stars (registry No. С162024015861) |
| Person responsible for personal data processing | Mubarakzyanova G. F.; telephone: +7 (937) 615-40-12; email: 5719901@bk.ru; gos-aviator@yandex.ru |
3. Purposes of personal data processing
| No. | Purpose | Legal basis (Part 1, Article 6 of Law No. 152-FZ) |
|---|---|---|
| 1 | Entering into, performing and terminating a hotel services agreement (booking, check-in, accommodation and payment) | Paragraph 5 — performance of a contract |
| 2 | Handling applications and enquiries submitted through the website’s contact forms | Paragraph 1 — the data subject’s consent |
| 3 | Complying with Russian law (migration registration, tax accounting and anti-money-laundering requirements) | Paragraph 2 — legal requirement |
| 4 | Ensuring safety and counter-terrorism security (video surveillance and access control) | Paragraph 2 — legal requirement |
| 5 | Sending booking- and stay-related notices (booking confirmations and reminders) | Paragraph 1 — the data subject’s consent |
| 6 | Marketing communications (newsletters about promotions and special offers), only with separate consent | Paragraph 1 — the data subject’s consent |
| 7 | Analysing website traffic and improving the website (web analytics) | Paragraph 1 — the data subject’s consent (through the cookie banner) |
4. Categories of data subjects
• Hotel guests (individuals who book and stay at the hotel);
• Visitors to gosaviator.ru (users who submit enquiries through the contact forms);
• Representatives of legal entities arranging corporate bookings;
• Persons accompanying guests (where minors or persons requiring assistance check in).
5. Personal data processed
For booking and accommodation:
• Surname, first name and patronymic;
• Date of birth;
• Identity document details (series, number, issuing authority and date of issue);
• Citizenship;
• Registered address (where required);
• Contact telephone number;
• Email address;
• Booking details (check-in and check-out dates, room category, number of guests and special requests);
• Payment details (payment method, amount and date);
• IP address and cookies (when using the website).
For enquiries submitted through the website:
• Name;
• Contact telephone number;
• Email address;
• Message content;
• IP address and cookies.
6. Methods of personal data processing
Data is processed both with and without automated means. Processing includes collection, recording, organisation, accumulation, storage, clarification (updating and alteration), retrieval, use, transfer (dissemination, provision and access), depersonalisation, blocking, deletion and destruction.
7. Processing and storage periods
| Purpose | Storage period |
|---|---|
| Booking and accommodation | Until the purposes of processing have been achieved, but no less than the period required by law |
| Contractual and financial documents | Up to five years after the contract ends (Russian Tax Code) |
| Migration registration data | In accordance with the requirements of the Russian Ministry of Internal Affairs |
| Website enquiries | Up to three years after the last contact |
| Marketing data | Until consent is withdrawn, but no longer than three years |
| Cookies | Up to one year from consent or until consent is withdrawn |
| Video surveillance recordings | Up to 30 days (if there has been no incident) |
8. Transfer of personal data to third parties
Data is transferred to the extent necessary for the purposes of processing:
| Recipient | Purpose of transfer | Basis |
|---|---|---|
| Russian Ministry of Internal Affairs (migration departments) | Migration registration of foreign nationals | Legal requirement |
| Russian Federal Tax Service | Tax accounting | Legal requirement |
| Payment services (Russian acquiring providers) | Accepting payments | Performance of a contract |
| Property management system (PMS) / booking module (if third-party software is used) | Booking automation | Data processing agreement |
| Yandex Metrica (subject to cookie consent) | Web analytics | Data subject’s consent |
Data is transferred to third parties under agreements requiring them to ensure the confidentiality and security of personal data.
9. Security measures
• Password protection of information systems;
• Antivirus protection;
• Encryption of data in transit (HTTPS / TLS);
• Data backups;
• Differentiated employee access to personal data;
• Restricted physical access to servers;
• Regular software updates;
• Appointment of a person responsible for personal data processing.
10. Cross-border transfers
Personal data is not transferred across borders. All databases containing personal data of Russian citizens are stored and processed on servers physically located in the Russian Federation. The hosting for gosaviator.ru is located in Russia.
11. Automated processing
The Operator does not make decisions that have legal consequences or otherwise affect data subjects’ rights solely on the basis of automated personal data processing. Human involvement is required in making such decisions.
12. Responding to data subject requests
Data subjects may contact the Operator about the processing of their personal data:
• By telephone, through the person responsible: +7 (937) 615-40-12; +7 (843) 211-90-52;
• By post: 9 Akademika Pavlova Street, Kazan 420127, Russia;
• By email: 5719901@bk.ru; gos-aviator@yandex.ru.
The Operator must consider the request and provide a reasoned response within 30 days of receiving it.
13. Destruction of personal data
When the purposes of processing have been achieved, the storage period has expired or consent has been withdrawn, the Operator:
• Blocks access to personal data;
• Destroys the data in information systems;
• Destroys physical copies, if any;
• Confirms destruction to the data subject upon request.
14. Date of last update
Last updated: 12 September 2026.
15. Amendments
The Operator may amend this Policy. The current version is published at gosaviator.ru. Users are notified of changes by publication of a new version on the website. Continued use of the website after changes are made signifies agreement with the updated Policy.
16. Depersonalisation
Personal data is depersonalised for statistical analysis of website traffic and service quality. Depersonalised data does not allow a particular data subject to be identified directly or indirectly.
17. Rights of data subjects
Data subjects have the right to:
• Obtain information about the processing of their data;
• Request that data be corrected, blocked or destroyed;
• Withdraw consent to processing;
• Lodge a complaint about the Operator’s actions with Roskomnadzor (7 Kitaygorodsky Proyezd, Building 2, Moscow 109074, Russia) or through the courts.