Publication date: December 3, 2019.

PRIVACY POLICY

This Personal Data Privacy Policy (hereinafter the Privacy Policy) is valid with regard to all information which "AWAD Ticket" LLC (hereinafter the Operator), located at www.anywayanyday.com, may receive in relation to the User during the use of the website, programs and products of "AWAD Ticket" LLC and its partners.

The Operator is a Personal Data Controller within the meaning of the provisions of the General Data Protection Regulation of the European Union (GDPR).

This Privacy Policy is an integral part of the Offer and User Agreement.

1. TERMS AND DEFINITIONS

1.1. The following terms are used in this Privacy Policy:

• Website shall mean a combination of the System, Content and other information contained in the "Internet" information system, the access to which is provided, inter alia, at www.anywayanyday.com;
• Services shall mean a set of services on arrangement of air and/or railway tickets, hotel room booking and other additional services provided to the User by means of the Platform.
• System shall mean the "www.anywayanyday.com" system (Certificate of state registration of a computer program No. 2013612738).
• Operator is the legal entity possessing and managing the Website that is organizing and (or) carrying out the Personal Data processing, as well as defining the purposes of the Personal Data processing, the contents of the Personal Data to be processed, the actions (operations) performed with the Personal Data.
• Personal Data shall mean any information directly or indirectly related to a identified or identifiable individual (personal data subject).
• Platform shall mean the Website and/or Mobile Application that belongs to and is controlled and managed by the Operator, by means of which the Services are provided.
• Personal Data Processing shall mean any action (operation) or set of actions (operations) performed on personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, verification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
• Personal Data Privacy shall mean a requirement not to allow Personal Data distribution without the consent of the subject of the personal data or presence of other legal grounds, which is mandatory for the Operator or other entity that has access to personal data.
• Website User (hereinafter the User) shall mean a person who has access to the Website through the Internet and who uses the Website.
• Order shall mean a filled out request of the User for the receiving of services chosen on the Website and related to the booking and purchasing of tickets at the desired price.
• Cookies shall mean a small fragment of data sent by the web-server and stored on the User's computer, which the web-client or the web-browser sends to the web-server in an HTTP-request upon each opening of a page of the corresponding Website.
• IP-address shall mean a unique network address of a node in a computer network that uses the IP protocol.

2. GENERAL PROVISIONS

2.1. Transfer of the personal data of the User to the Operator is voluntary.

The use of the Website by the User means acceptance of this Privacy Policy and the terms of the User's personal data processing.

2.2. In case of disagreement with the terms of the Privacy Policy, the User must immediately stop using the Website.

2.3. This Privacy Policy applies only to the Website. The Operator does not control and is not responsible for third-party websites to which the User can go following the links available on the Website.

2.4. The Operator does not verify the accuracy of the personal data provided by the User.

3. SUBJECT MATTER OF THE PRIVACY POLICY

3.1. This Privacy Policy establishes the obligations of the Operator for non-disclosure and ensuring the protection of the confidentiality of the personal data that the User provides at the request of the Operator when registering and/or placing an Order on the Website.

3.2. The Personal Data permitted to be processed under this Privacy Policy is provided by the User by filling out registration or authorization forms on the Website and may include the following information:

• surname, name, patronymic of the User;
• sex;
• citizenship;
• contact phone number of the User;
• e-mail;
• details of identification documents (number, date of issue, date of expiry, issuing authority);
• place of residence of the User;
• payment card detail (payment card number, CVC/CVV code, name and surname of the owner of the card, date of issue, date of expiry);
• User's content (commentaries left by the User on the Website);
• other information voluntarily left by the User on the Website.

3.3. The Operator protects the data that is automatically transmitted during the viewing of advertising blocks and when visiting pages on which a statistical script of the system is set up ("pixel"):

• IP address and country of its registration;
• information from cookies;
• information about the browser (or other program which exercises access to ad impression);
• time of access;
• address of the page on which the ad block is placed;
• referrer (address of the previous page);
• other data gathered by analytic counters of third-party organizations set up on the Website. This data is anonymous in nature and is aimed at improving the User experience, improving the usability of the Website and traffic analysis.

This data is collected automatically, the sending of this data can be prevented by disabling cookies in the browser in which the Website is opened.

3.3.1. Disabling cookies may result in inability to access parts of the Website that require authorization.

3.3.2. The Operator collects statistics about Users' IP addresses. This information is used to identify and solve technical problems, to control the legality of the financial payments effected.

3.4. Any other personal information not mentioned above (purchase history, browsers used and operating systems, etc.) is subject to safe storage and non-disclosure, except as provided in clauses 6.2. and 6.3. of this Privacy Policy.

3.5. In order to fulfill the Order, the Operator has the right to request additional information from the User, which may include confidential personal data, in particular the information about the state of health.

3.6. If the User makes air tickets reservations and/or purchases additional services on behalf of third parties or for third parties, the Operator collects, processes and transfers personal data and the information provided by the User about these third parties on the same terms as it collects, processes and transfers the personal data and information about the User. At the same time, by providing personal data and information about third parties, the User confirms that these persons are aware of these terms, understand the consequences of these actions and express full and unconditional consent to the collection, processing, storage and transfer of their personal data.

4. PURPOSES OF GATHERING THE USER'S PERSONAL DATA

4.1. User's Personal Data can be used by the Operator in order to:

• provide a complex of services by means of the Platform;
• consider applications and complaints;
• provide security of the provided services and prevent fraudulent activities;
• improve the quality of the Platform's operation, improve its usability, develop new products and services;
• personalize the interaction with the Users of the Platform;
• send information on services, status of their provision, as well as on special offers, discounts, news and promotional offers of the Operator and its partners through the communication channels;
• promote the Platform Services in the market through direct contact with Users by means of communication networks;
• conduct statistical and analytical research for marketing and strategic purposes of the Operator.

4.2. The provision of the Operator's services is impossible without the provision of all necessary personal data by the User.

5. MEANS OF OBTAINING PERSONAL DATA

5.1. During registration/authorization, including by means of social networks, the User is required to provide the following personal data:

• e-mail;
• password;
• other data gathered by analytic counters of third-party organizations set up on the Website.

5.2. When subscribing to the newsletter, the User is requested to provide the following personal data:

• e-mail;
• other data gathered by analytic counters of third-party organizations set up on the Website.

5.3. When booking/purchasing an air or railway ticket or a hotel (hereinafter the Services) or additional services, the User is requested to provide the following personal data:

• surname, name, patronymic;
• sex;
• date of birth;
• citizenship;
• details of identification documents (number, date of issue, date of expiry, issuing authority);
• contact phone number of the User and other persons, at the discretion of the User;
• e-mail;
• payment card details (payment card number, CVC/CVV code, name and surname of the owner of the card, date of issue, date of expiry);

This information is necessary for the provision of Services or additional services in order to further identify the User as a passenger.

5.4. When placing an Order for the Services, an account\personal profile of the User is created automatically. In the future, when logging into your personal profile, your activity on the Operator's website will be tracked and linked to the User account.

5.5. When the User downloads and uses the existing or future mobile applications of the Operator, the Operator will receive a unique device identifier, and all information about the User's activities will be linked to this unique device. Moreover, the Operator may monitor and collect data on the use of applications – for example, the date and time when the application on the User's device accesses the Operator's servers and what information and files have been downloaded to the application, and this information may be linked to the User's account.

5.6. The Operator also collects information about the User off-line, for example, when the User calls the Support Service.

5.7. The operator collects information about the type of the browser and device through the User's device, such as hardware (MAC) address, computer type, screen resolution, name and version of the operating system, manufacturer and model of the device, language, type and version of the web browser.

5.8. The Operator, service providers, as well as any advertising networks that assist the Operator with the provision of relevant ads to the User may use cookies, pixel tags, and other similar technologies to evaluate and track the overall activity of the User on the Website and third-party websites.

5.9. The Operator receives information about the User from third - party companies acting as providers of analytical services. These analytical services use cookies and similar technologies to analyze the User's actions of using the Operator's services and compile statistical reports. These services may also collect information about the use of other websites by the Users of the Operator's services.

5.10. When a User uses the Website, the IP address of the User's device is automatically identified and registered in the server log files, as well as the time of the User's visit of the Website and its specific pages.

6. MEANS AND TERMS OF PERSONAL DATA PROCESSING

6.1. The processing of personal data of the User is carried out without limitation of time, in any lawful way, including in  personal data information systems by automatic means or without using such means.

6.2. The User agrees that the Operator has the right to transfer personal data to third parties, in particular to:

• service providers, such as transporters, providers of hotel services, auto rental services or agents acting on behalf of providers to ensure the provision of the Services ordered;
• service organizations involved for the provision of services to the User, including payment processing, prevention of fraudulent activities, conduction of business analysis and marketing research, as well as User service;
• business partners, in cooperation with which the Operator offers certain products and services;
• state authorities, when it is necessary by virtue of law for legal proceedings, satisfaction of judgments and other legal processes, as well as in order to receive evidence or uphold the Operator's legal rights;

exclusively for the purposes established by section 4 of the Privacy Policy.

6.3. User's Personal Data can be transferred to authorized state bodies only on the grounds and in the manner provided for by the legislation of the Russian Federation.

6.4. In case of loss or disclosure of personal data, the Operator informs the User about the loss or disclosure of personal data.

6.5. The Operator shall take the necessary organizational and technical measures to protect the User's personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

6.6. The Operator jointly with the User takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

7. OBLIGATIONS OF THE PARTIES

7.1. The User undertakes to:

• provide the information about personal data necessary for the use of the Website;
• update, complement the provided information about personal data in case of changes in such information;
• immediately inform the Operator about the use of the User's account by third parties without the User's consent.

7.2. The Operator undertakes to:

• use the information obtained exclusively for the purposes specified in clause 4 of this Privacy Policy;
• ensure storage of confidential information in secret, not to disclose it without the prior written permission of the User, and not to sell, exchange, publish or disclose in other possible ways the transferred personal data of the User, except as provided for by clauses 6.2. and 6.3. of this Privacy Policy;
• take precautions to protect the confidentiality of the User's personal data in accordance with the procedure commonly used to protect such information in existing business practice;
• block the personal data related to the relevant User from the moment of an application or request of the User or the User's legal representative or authorized body for the protection of the personal data subjects' rights for the period of verification, in case of detection of inaccurate personal data or illegal actions;
• store the User's personal data for the period of time necessary for the purposes specified in this Privacy Policy, unless a longer storage period is necessary in accordance with applicable law.

8. LIABILITIES OF THE PARTIES

8.1. Upon non-fulfillment by the Operator of its obligations, it shall be liable for losses incurred by the User in connection with the misuse of personal data in accordance with the legislation of the Russian Federation, except for the cases provided for in clauses 6.2., 6.3. and 8.2. of this Privacy Policy.

8.2. In case of loss or disclosure of the Confidential Information, the Operator shall not be liable if such Confidential Information:

• became publicly available before its loss or disclosure;
• had been obtained from a third party before it was disclosed by the Operator;
• was disclosed upon the consent of the User.

9. CROSS-BORDER DATA TRANSFER

9.1. As an air ticket sales agent, the Operator transfers personal data to providers of the Services and additional services located around the world in order to perform its function. In this regard, Personal Data of the Users may be stored and processed in any country where the Operator has representative offices, or in which the Operator involves providers of the Services and additional services.

9.2. By using the Website the User consents to the transfer of the Personal Data outside the country of residence of the User to other countries, where other laws on the protection of information, different from the laws of the country of residence of the User, may apply.

10. ADDITIONAL TERMS AND CONDITIONS

10.1. The Operator has the right to change this Privacy Policy without the consent of the User.

10.2. A new Privacy Policy comes into effect from the moment of its publication on the Website, unless otherwise stipulated by a new edition of the Privacy Policy.

10.3. Any complaints, suggestions or questions regarding this Privacy Policy should be sent to the following email address: privacy@anywayanyday.com

10.4. This Privacy Policy is available on the page at: https://www.anywayanyday.com/cms/pages/legal-documents/.

11. CONTACT DATA

11.1. "AWAD Ticket" LLC is a legal entity established and operating in accordance with the legislation of the Russian Federation and registered at: 115114, Moscow, Derbenevskaya Embankment, 7, building 12, floor 2

OGRN (Primary State Registration Number): 1097746010724

E-mail: privacy@anywayanyday.com.

PERSONAL DATA PROCESSING POLICY dated 28.06.2019

PERSONAL DATA PROCESSING POLICY dated 01.07.2017