Tours of Moscow is committed to protecting your privacy and the confidentiality of your personal information.
This Privacy Statement applies to all websites operated by Tours of Moscow. This statement explains, in further detail, the types of personal information we collect, how we collect, use and disclose this information, the steps we take to protect information, how you can access and change your personal information and how you can make a privacy complaint.
Tours of Moscow processes personal information both as a Processor and as a Controller, as defined in the European Union General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR).
Tours of Moscow is not responsible for the content, policy or practices of websites operated by third parties that are linked to this website. Links to third party sites do not constitute sponsorship, endorsement or approval by Tours of Moscow of the content, policies or practices of those third party sites. When you follow a link from this website to another website, we recommend you read and consider the privacy statement of that website.
In accordance with the Privacy Act, this Statement uses the following definitions:
(a) An entity «collects» personal information only «if the entity collects the personal information for inclusion in a record or generally available publication».
(b) Direct marketing involves the use and/or disclosure of personal information to communicate directly with an individual to promote goods and services. A direct marketer may communicate with an individual through a variety of channels, including telephone, SMS, postal mail, e-mail and online advertising.
(c) An entity “discloses” personal information “when it permits that information to become known outside the entity and releases it from its effective control”.
(d) An entity “holds” personal information “if the entity has possession or control of a record that contains personal information”.
(e) «Personal information» means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
(f) «Primary purpose» refers to the particular purpose for which the information in question was collected.
(g) «Secondary purpose» is any purpose other than the primary purpose for which we have collected your personal information.
(h) «Sensitive information» means information or an opinion about an individual’s personal preferences or characteristics (such as race, ethnicity, political views, memberships, religious or philosophical beliefs and sexual preference), health information and/or biometric information.
(i) An entity “uses” personal information “where personal information is handled, or an activity is undertaken with the information, within the entity”.
What kinds of information do we collect and/or hold?
The types of personal information that Tours of Moscow may collect and hold includes the following:
(a) full name, postal address, e-mail address, telephone and fax numbers;
(c) date of birth, gender and marital status;
(d) any other information you provide to us by any means; and
(e) information associated with web browsing, such as your IP address.
Generally, the kinds of information that Tours of Moscow will collect and/or hold will depend on the kind of project or development we are concerned with – essentially, the purpose of the activity we are conducting. Accordingly, the kinds of information we record will usually simply extend to your name, and applicable contact details.
On occasion we may collect and/or hold other kinds of information – such as when we run a promotional event or a competition. When we do this, we will disclose our intention to do so to you.
How do we collect your personal information?
Tours of Moscow may collect personal information from or about you in a number of circumstances, including:
(a) from publicly available sources of information;
(b) when you use our services or contact us directly;
(c) when you sign up to receive information from us;
(d) when you take part in one of our competitions and/or promotions;
(e) when you use our website and/or via software, such as cookies and web/tracking pixels (also known as “web beacons”);
(f) when you provide or offer services to us;
(g) from third parties;
(h) from our own records at Tours of Moscow; and
(i) when legally required to do so.
Protecting the privacy of children is especially important. Tours of Moscow will not knowingly collect personal data from children under the age of 16 without obtaining parental consent.
You can browse the general content of Tours of Moscow’s website anonymously, without disclosing your personal information. However, some functionality on this website may require you to provide personal information.
For example, when you register your interest or otherwise in the course of us providing services to you, Tours of Moscow may need to collect personal information which may include your name, address, telephone/mobile phone number, e-mail address, credit card details, your business name, your user ID or password.
Subject to legal constraints or obligations, Tours of Moscow will, at all times, take reasonable steps to collect your personal information directly from you, unless:
(a) it is unreasonable or impracticable for us to do so; or
(b) you consent to the collection of the information from someone other than you.
Tours of Moscow only collects (and holds) sensitive information when knowingly and voluntarily submitted by you. Although Tours of Moscow will rarely hold and/or collect this kind of information, the information Tours of Moscow may hold includes your family status and/or other information about you, such as your passport number. Subject to any legal constraints or obligations, Tours of Moscow will, at all times, take reasonable steps to obtain your express consent where Tours of Moscow proposes to handle your sensitive information.
Notification of collection
When Tours of Moscow collects personal information about you, it will take reasonable steps to notify you or to otherwise ensure you are aware of certain matters. These matters include our identity as an organisation and contact details, the context of the collection, whether the collection is required or authorised by law, the purposes of the collection, Tours of Moscow’s usual disclosure of personal information, information about our Privacy Statement and whether Tours of Moscow is likely to disclose your personal information to overseas recipients.
Tours of Moscow will take reasonable steps to provide this notification before, or at the time it collects your personal information. If it is not possible for it to do so, Tours of Moscow will take reasonable steps to provide notification as soon as practicable after collection.
In the event we receive your personal information from a third party, via referral and/or via a purchase list, we will take reasonable steps to inform you of that and seek your consent to our collection of that information. Should you refuse to consent to that collection, we will take reasonable steps to destroy or de-identify that information.
When you browse and make use of Tours of Moscow’s social media pages (such as Facebook, Twitter, YouTube and Instagram), you are using an external site and are therefore subject to the privacy policies and practices of that site. If you have any questions or concerns regarding that site’s privacy policies and practices, you should review the privacy statement of the relevant site. Tours of Moscow does not exercise any control over the management of those sites. Tours of Moscow does not endorse, and is not accountable for, any views expressed by third parties using those sites.
Tours of Moscow records all information posted to its social media pages and uses that information for the purposes of administering the pages, for record keeping, for considering and/or addressing any comments made and for running competitions and campaigns. No attempt will be made to further identify social media subscribers except where requested and authorised by law.
How do we hold and store your information?
All of the personal and sensitive information we collect is stored locally on our network storage and on a locally based cloud system. All information is backed up which is held in a safe environment.
Tours of Moscow also maintains a number of hardcopy collections of records and electronic databases for use by staff, these include:
(a) project files;
(b) administration files (e.g. finance, strategic planning, information technology);
(c) human resource management files; and
(d) a library collection.
Current files are held on site. The library collection consists of books, journals and reports produced by or for Tours of Moscow in relation to its projects. The collection is maintained onsite with non-current documents archived in a similar manner to files. Access to the library collection is on a similar basis to that for files.
Tours of Moscow strives to ensure the security, integrity and privacy of the personal and sensitive information of its clients. Tours of Moscow takes reasonable steps to protect the security of all personal information.
Tours of Moscow personnel are required to respect the confidentiality of personal information and the privacy of individuals.
Tours of Moscow use a variety of physical and electronic security measures, including restricting physical access to our offices and firewalls and secure databases to keep personal information secure from misuse, loss or unauthorised use or disclosure. In relation to personal information provided through Tours of Moscow websites, unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.
Tours of Moscow continually reviews its various security measures in order to ensure that they are up to date and fit for purpose. Unsolicited personal information is information received where the entity has taken no active steps to collect the information. When and where Tours of Moscow receives unsolicited information Tours of Moscow will need to determine whether the unsolicited information should properly be retained as a record of Tours of Moscow. Where Tours of Moscow determines that the unsolicited information is not properly a record of Tours of Moscow, Tours of Moscow will destroy the information as soon as practicable, so long as it is lawful and reasonable to do so.
Information retention and destruction practices or obligations
What are cookies?
A cookie is a small text file stored on your computer’s browser. Many cookies from websites will be visible from your browser. You will usually find information on cookies and how to manage them under “options” or “settings” in your browser. You can choose to see cookies before deleting them and to keep cookies from some sites.
There are several different types of cookies (some of which are used on Tours of Moscow’s website):
Most of the information collected by cookies will not be sufficient to identify you – this is because the information collected will be very “general” in nature, relating to your interests (i.e. the products you have looked at) and the websites you have visited previously. Information collected via cookies will only be deemed to be “personal information” if you or any other individual are identified or reasonably identifiable.
Tours of Moscow will not facilitate the merging of personally-identifiable information with non-personally identifiable information collected through any cookies, tracking/web pixels or Google advertising products or features, unless it has robust notice of and the relevant party’s consent to that merger.
Third party cookies
Third party cookies are sent by different organisations (such as businesses which provide content such as advertising) to the owner of the website you are visiting – so in this instance this means by organisations other than Tours of Moscow.
Third party cookies are used on Tours of Moscow’s website to enable remarketing and reporting for impression assisted visits, website conversions, user demographics and user interests.
The third party cookies we use on our website include (but are not limited to):
Google and Adobe will use the information transmitted to it for the purposes of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google and Adobe may transfer this information to third parties where it is required to do so by law or where such third parties process the information on Google and Adobe ’s behalf.
The Google advertising cookies are used to, among other things: select advertising for users based on what is relevant to them, to improve reporting on campaign performance and to avoid showing ads the user has already seen.
For example, if an e-commerce company wishes to pay affiliates based on how many items are purchased on their site, they would need some way to correlate the purchases on their site with the advertisements that were viewed or clicked on the affiliate site – the pixel enables the e-commerce company to do this.
Tours of Moscow makes use of this tracking/web pixel to run and facilitate the campaigns and competitions it runs via Facebook. The tracking/web pixel allows Tours of Moscow to track the “conversions” that happen as a result of Tours of Moscow’s Facebook advertisements.
How can I manage, reject and/or delete cookies?
As noted above, Tours of Moscow sometimes links to or embeds content from other websites and organisations such as Facebook and YouTube. Tours of Moscow does not control the dissemination of third party cookies from these sites. In order to manage and/or reject and delete third party cookies, you will need to refer to the privacy policies of the relevant third party website(s).
If you want to control or opt out of the operation or application of Google Analytics and/or the Google Analytics Advertising Features, you should refer to Google’s guide(s) on opting out of those features at: http://www.google.com/intl/en/policies/privacy/.
How and in what circumstances will Tours of Moscow use or disclose my personal information?
Tours of Moscow may, in certain circumstances, collect, hold, use and/or disclose your personal and/or sensitive information. Tours of Moscow will be taken to have disclosed personal information when it permits that information to become known outside Tours of Moscow and where it releases it from its effective control. For example, Tours of Moscow would be said to have disclosed your personal information where:
(a) it shares your personal information with another entity;
(b) it publishes your personal information on the internet so it is accessible by others;
(c) where one of its staff reveals your personal information in the course of a conversation with a person who does not work for Tours of Moscow; or
(d) where one of its staff members sends a document containing your personal information to someone who is not you.
In the event Tours of Moscow discloses information, Tours of Moscow will make a written record of the use or disclosure.
Your personal and/or sensitive information will only be used and disclosed for the primary purpose for which it was submitted or for such other secondary purposes that are related to that purpose, unless we disclose other uses in this Privacy Statement or at the time of the collection of that information.
When collecting your information we will inform you of the primary purpose of our collection and/or any anticipated secondary purpose that may arise. The purpose of our collection will vary from project to project, depending on the nature of the project and the nature of your involvement and/or interest in the project.
Tours of Moscow will use and disclose your personal information to provide our services to you or to fulfill administrative functions associated with these services. In general, we will use and disclose your personal information for the following purposes:
(a) to notify you about an event you may wish to be involved in;
(b) to communicate with you with respect to an existing event or booking;
(c) to provide and market our services;
(d) to help us manage and enhance our services;
(e) to purchase from you;
(f) for any purpose for which the information was provided; or
(g) any other purpose related to any of the above.
46 We will only make use of or disclose your personal information for a secondary purpose if:
(a) you have consented to the use or disclosure of that information; or
(b) you would reasonably expect Tours of Moscow to use or disclose the information for the secondary purpose; or
(c) the use or disclosure of that information is required or authorised by or under legislation or court/tribunal order; or
(d) a “permitted general situation” exists in relation to the use or disclosure of the information by Tours of Moscow; or
(e) Tours of Moscow reasonably believes that the use of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
Apart from the primary and secondary purposes outlined above, personal information may be disclosed in special situations where Tours of Moscow have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities. It may also be used as required by legislation in the Russian Federation. Finally, Tours of Moscow may disclose personal information when it believes in good faith that the law requires disclosure.
Tours of Moscow will not use or disclose your personal information for the purpose of direct marketing, unless:
(a) we collected the information from you;
(b) we obtained your consent to the use or disclosure of the information for that purpose (except where it was impracticable to do so); and
(c) you would reasonably expect Tours of Moscow to use or disclose the information for that purpose; and
(d) we provide you with an easy to use means of opting out of receiving any further direct marketing communications; and
(e) you have not requested that we cease sending you direct marketing communications.
As mentioned above, Tours of Moscow makes use of a number of Google Analytics Advertising Features, including remarketing. The Remarketing feature allows Tours of Moscow to reach people who have previously visited its website and to match users with appropriate advertising.
If you would like to control or opt out of the application of the Google Analytics Advertising Features, you should refer to Google’s guide(s) on opting out of those features.
Tours of Moscow will only make use of your sensitive information for direct marketing purposes if you have consented to the use or disclosure of that information for that purpose.
If you receive direct marketing communications from Tours of Moscow or from an associated entity, you are entitled to:
(a) request that you receive no further direct marketing communications for Tours of Moscow
(b) and/or the associated entity; and
(c) request that Tours of Moscow disclose the source of the information.
Tours of Moscow will take reasonable steps to facilitate a request by you to opt-out of receiving direct marketing communications. This may be a request to opt-out of receiving certain communications or to opt-out altogether. Tours of Moscow will not charge you for making such a request or for giving effect to such a request.
Tours of Moscow will take reasonable steps to give effect to such request within a reasonable period of time after the request is made and will reply to a request for the source of the information in a reasonable period of time (unless it is unreasonable or impracticable for us to do so).
We may use your e-mail address to send you Tours of Moscow publications, newsletters, seminars or events. We may also contact you by e-mail to seek your opinion or comment on our website and our service offerings.
Tours of Moscow, at all times, aims to comply with best practice regarding “spam” and will not send unsolicited commercial electronic messages or “spam”.
All commercial electronic messages sent by Tours of Moscow include information about the individual or organisation who authorised the sending of the message. You can unsubscribe from our e-mails at any time. You can also contact us and instruct us not to send further information to you.
Disclosure to overseas recipients
Generally, Tours of Moscow does not disclose the personal and/or sensitive information of its customers to overseas recipients. However, there is a possibility that, on occasion, your personal information may be disclosed to an overseas recipient. The location of any recipients will vary depending on the project or purpose concerned.
In the event that a particular project or development will or may involve the disclosure of personal or sensitive information to an overseas recipient, Tours of Moscow will take reasonable steps to inform you of that potential use or disclosure as soon as possible. As part of our notification process, Tours of Moscow will inform you of the location and/or identity of that recipient.
Similarly with other third party recipients and/or partners of Tours of Moscow, we will take reasonable steps to ensure and/or encourage any overseas recipients to comply with privacy policies and regulations which are similar to or more strenuous than those required by applicable Russian legislation. However, it is not possible for Tours of Moscow to compel them to do so.
Should you have any queries about the potential disclosure of your personal information to an overseas recipient, please contact us via email.
Who can access my personal information and what conditions apply to their use of my personal information?
As a general rule, your personal and sensitive information will only be accessed and/or viewed by Tours of Moscow staff and officers, as and when it is appropriate or necessary. However, your personal information may also be accessed, from time to time, by:
(a) Tours of Moscow contractors;
(b) Tours of Moscow project partners; or
(c) Tours of Moscow suppliers.
Where a party, other than an employee or officer of Tours of Moscow, has access to the personal information of individuals, they will be required to comply with applicable privacy legislation and, where appropriate, to enter into Privacy Agreements with Tours of Moscow.
The access and use of your personal or sensitive information by a third party will be restricted to the purpose for which it was first collected and/or to a closely related secondary purpose.
In some limited circumstances we may also need to use or disclose personal information for other specific purposes, including:
(a) where Tours of Moscow reasonably believes that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conduct by or behalf of an enforcement body; or
(b) where required to do so by or under a law of the Russian Federation or a court or tribunal order, for example n response to a subpoena.
How can you access your personal information and/or seek the correction of your personal information?
You can make a request for access to your personal information informally in writing. If you are in the EU, you may request access pursuant to the terms of Article 15 of the GDPR. Tours of Moscow aims to, whenever possible, facilitate informal requests for personal and/or sensitive information.
Tours of Moscow will take reasonable steps to respond to a request for access within a reasonable period of time after the request is made (within 45 days) and to give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so.
In the event that Tours of Moscow refuses to give you access to the personal information requested by you, we will give you a written notice which sets out the reasons for the refusal (except to the extent that it would be unreasonable to do so) and the mechanisms available to you to complain about the refusal.
Requests for access must be lodged by email.
Tours of Moscow reserves the right to impose minimal charges for providing you with your personal information if it forms the view that your request is unfounded or excessive.
Should you experience difficulty in determining the correct route through which to request access to your personal information, please contact us by email and we will endeavour to assist you.
Request for correction of personal information
You can make a request for the correction and/or amendment of your personal information informally in writing. Applications to have personal information held by Tours of Moscow corrected or amended should:
(a) be made in writing to the company;
(b) provide enough information to determine what changes are required; and
(c) provide your current contact details.
In the event Tours of Moscow refuses to correct your personal information, Tours of Moscow will give you a written notice which sets out the reasons for the refusal (except to the extent it would be unreasonable to do so) and the mechanisms available to you to complain about the refusal.
Tours of Moscow will take reasonable steps to respond to a request for access within a reasonable period of time after the request is made (within 45 days) and will not charge you for the making of the request or for the correction of the personal information.
You rights in the EU
Subject to legal constraints, including Tours of Moscow’s obligations if you are in the EU your principal rights under the GDPR are:
(a) the right to be informed;
(b) the right to access;
(c) the right to rectification;
(d) the right to erasure, i.e to be forgotten;
(e) the right to restrict processing;
(f) the right to object to processing;
(g) the right to data portability; and
right to not be subject to automated decision making.
You can read the relevant laws and guidance from the regulatory authorities under the GDPR for a full explanation of these rights.
Notifiable data breaches
We are committed to protecting information we hold about you, and to compliance with the Notifiable Data Breaches scheme. Where we become aware of a potential data breach which is likely to result in serious harm to any individuals about whom we hold information, we will:
How can I complain about a breach or give feedback on how Tours of Moscow deals with my personal information?
Should you wish to provide Tours of Moscow with feedback with respect to its management of your personal information, to complain about a breach of Tours of Moscow’s privacy obligations or to appeal a decision with respect to a request for access to or the correction of personal information, please contact us by email.
Tours of Moscow will take reasonable steps to respond to your complaint and/or feedback within 45 days. In the event that you wish to have a decision refusing access to your personal information and/or refusing to correct your personal information reviewed or to lodge a complaint with respect to the management of your personal information, please contact us via email.