Policy on Personal Data Processing and Protection

1. General Provisions

   This Personal Data Processing and Protection Policy has been developed in accordance with Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data", as well as other regulatory legal acts of the Russian Federation.

   The personal data operator: TRASYS Limited Liability Company (TRASYS LLC), TIN 1800037763, KPP 180001001, OGRN 1251800008745, registered address: 426075, Russian Federation, Udmurt Republic, Izhevsk, Molodezhnaya st., 76, apt. 1, email: support@trasys.ru (hereinafter referred to as the "Operator").

   The Operator processes personal data in compliance with the principles of legality, minimization, and security, respecting the rights and freedoms of individuals. The Policy applies to all information received from users of the website https://www.tisland.travel/ (hereinafter referred to as the "Website").

2. User Personal Information

   Under this Policy, personal information includes:

   1. Data provided by the User voluntarily:
      • last name, first name, patronymic;
      • date of birth;
      • phone number;
      • email address;
      • other information submitted through forms on the Website.
   2. Data automatically transmitted when using the Website:
      • IP address;
      • cookies;
      • browser and device data;
      • technical characteristics;
      • date and time of access;
      • addresses of requested pages.

   The Policy applies only to the Website. The Operator is not responsible for third-party websites.

3. Principles of Personal Data Processing

   Personal data processing is carried out:

   • on a lawful and fair basis;
   • for specific, predetermined purposes;
   • without combining databases with incompatible processing purposes;
   • in the volume necessary to achieve the purposes;
   • ensuring the accuracy and relevance of data;
   • for the period necessary to achieve the processing purposes.

   Personal data is destroyed or anonymized upon achievement of processing purposes or when the need for achieving them is lost.

4. Purposes of Personal Data Processing

   The Operator processes personal data for the purposes of:

   • preparation, conclusion, and performance of contracts;
   • provision of services;
   • User identification;
   • sending notifications;
   • promotion of goods and services (with consent);
   • compliance with the requirements of Russian Federation legislation.
5. Legal Basis for Processing

   Personal data processing is carried out on the basis of:

   • Federal Law No. 152-FZ;
   • Federal Law No. 149-FZ;
   • the Civil Code of the Russian Federation;
   • other regulatory acts of the Russian Federation;
   • contracts with Users;
   • consent of the personal data subject.
6. Conditions for Personal Data Processing

   Processing is carried out:

   • with the consent of the personal data subject;
   • without consent in cases expressly provided for by law;
   • in the course of contract performance;
   • to protect the legitimate interests of the Operator.

   Consent is deemed given when the User checks the corresponding checkbox on the Website. In cases provided by law, consent is formalized in writing or as an electronic document with an electronic signature.

7. Delegation of Processing to Third Parties

   The Operator may delegate personal data processing to third parties on the basis of a contract. Such parties are obligated to:

   • comply with personal data legislation requirements;
   • ensure the confidentiality of information;
   • take necessary protective measures;
   • notify the Operator of security breaches.

   The Operator bears responsibility to the personal data subject, unless otherwise provided by law.

8. Transfer of Personal Data

   Transfer of personal data is possible:

   • with the User's consent;
   • for the performance of a contract;
   • as required by law;
   • in case of business reorganization or sale (with preservation of processing conditions).

   Personal data is not transferred to third parties without lawful grounds.

9. Personal Data Protection Measures

   The Operator takes necessary organizational and technical measures, including:

   • restricting access to personal data;
   • using secure data transmission channels;
   • internal processing regulations;
   • monitoring compliance with legal requirements;
   • regular assessment of security threats.

   In the event of an incident, the Operator notifies personal data subjects within the timeframe established by law.

10. Rights of Personal Data Subjects

    The personal data subject has the right to:

    • receive information about the processing of their data;
    • request correction, blocking, or destruction of data;
    • withdraw consent;
    • appeal the Operator's actions to Roskomnadzor or through the courts.

    Requests should be sent to: support@trasys.ru.

11. Dispute Resolution

    Before going to court, submitting a claim is mandatory. A response to the claim is provided within 7 calendar days. Disputes are resolved in accordance with the legislation of the Russian Federation.

12. Confidentiality

    The Operator and persons with access to personal data are obligated to maintain confidentiality and not disclose personal data without lawful grounds.

13. Final Provisions

    The Policy is effective indefinitely until a new version is approved. The Operator reserves the right to amend the Policy. The current version is published on the Website: https://www.tisland.travel/. All questions should be directed to: support@trasys.ru.