1. General Provisions

1.1. This Policy defines the goals, objectives, and key measures to ensure the security of personal data of UNI SKY LLC (hereinafter referred to as the Company or UNI SKY LLC) from unauthorized access, misuse, or loss. The User Agreement of UNI SKY LLC forms an integral part of this Privacy Policy and is a part thereof. This policy regarding the processing and protection of personal data applies only to the website https://unisky.aero/. The Company does not control and is not responsible for third-party websites to which the User may access links available on the website https://unisky.aero/.

1.2. This Policy has been developed in accordance with the current legislation of the Russian Federation in the field of personal data protection:

1.2.1. Federal Law of July 27, 2006 No. 152-FZ "On Personal Data."

1.2.2. Resolution of the Government of the Russian Federation of September 15, 2008 No. 687 "On Approval of the Regulation on the Specifics of Personal Data Processing Carried Out Without the Use of Automation."

1.2.3. Resolution of the Government of the Russian Federation of November 1, 2012 No. 1119 "On Approval of Requirements for the Protection of Personal Data When Processed in Personal Data Information Systems."

1.3. This Regulation forms the basis for the development of local regulations of UNI SKY LLC to ensure the security of Personal Data.

1.4. This Regulation applies to employees of UNI SKY LLC, employees of third-party organizations interacting with UNI SKY LLC, and persons who have subscribed to the newsletter, based on the relevant regulatory, legal, and organizational documents.

1.5. The processing of personal data of persons who have subscribed to the advertising mailing list and/or advertising information is carried out on the basis of the consent they have provided to UNI SKY LLC for the processing of personal data in accordance with Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as 152-FZ).

1.6. Email addresses and telephone numbers received by the Company may be used by the Company to send messages to users, including newsletters with the right to communicate to the Personal Data Subject any commercial and/or non-commercial information regarding the provision of promotional services and/or to send advertising and informational materials by sending newsletters via email, SMS messages via communication tools, and messages via the Telegram messenger to the Personal Data Subject. Users of the Company may unsubscribe at any time in the future, using the form specified in the sent newsletter and/or by sending a message to: info@unisky.aero.

1.7. The Company is not obligated to verify the accuracy of the information provided by the User and does not exercise control over the User's legal capacity. In this case, the Company assumes that the User provides accurate and sufficient personal information in the appropriate fields indicated in the registration form and that the User maintains this information up to date. The risk of providing inaccurate information is borne by the User who provided it.

2. Terms and Abbreviations

Personal data (PD) – any information relating to a directly or indirectly identified or identifiable individual (personal data subject).

Personal data processing – any action (operation) or set of actions (operations) performed with or without the use of automated means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

Automated processing of personal data – the processing of personal data using computer technology. Personal data information system – a set of personal data contained in databases and the information technologies and technical means that support their processing.

Personal data made publicly available by the personal data subject – PD, access to which is granted to an unlimited number of persons by the personal data subject or at their request. Blocking of personal data is the temporary cessation of processing of personal data (except in cases where processing is necessary to clarify the personal data).

Destruction of personal data is an action that makes it impossible to restore the contents of personal data in a personal data information system and/or results in the destruction of tangible media containing personal data.

3. Processing of Personal Data

3.1. Obtaining Personal Data.

3.1.1. All Personal Data must be obtained directly from the data subject. If a data subject's Personal Data can only be obtained from a third party, the data subject must be notified of this or their consent must be obtained.

3.1.2. The operator must inform the data subject of the purposes, intended sources, and methods of obtaining the Personal Data, the list of actions to be performed with the Personal Data, the period during which consent is valid and the procedure for its revocation, as well as the consequences of the data subject's refusal to provide written consent to obtain the Personal Data.

3.1.3. Documents containing Personal Data are created by:

• copying original documents (passport, education certificate, Taxpayer Identification Number (TIN), pension certificate, etc.);
• entering information into accounting forms;
• obtaining original copies of required documents (employment records).

3.2. Processing of Personal Data.

3.2.1. Personal data is processed:

• With the consent of the personal data subject to the processing of their personal data;
• In cases where the processing of personal data is necessary for the implementation and performance of functions, powers, and duties imposed by the legislation of the Russian Federation;
• In cases where the processing of personal data is made publicly available to an unlimited number of persons by the personal data subject or at their request (hereinafter referred to as personal data made publicly available by the personal data subject).

3.2.2. Purposes of Personal Data Processing:

To comply with the requirements of Russian Federation legislation (including accounting and personnel records, as well as Russian labor legislation); to fulfill contractual obligations to the Subjects of UNI SKY LLC when providing services for the reservation of aircraft; individual seats on an aircraft.

3.2.3. Categories of personal data subjects:

belonging to: individuals currently (or previously) employed by UNI SKY LLC, close relatives of employees, job applicants, individuals applying for services and persons specified in contracts, as well as individuals who submitted a request for feedback on the UNI SKY LLC website.

3.2.4. Personal data processed by UNI SKY LLC:

• Data obtained in the course of employment relationships;
• Data obtained in the course of civil law relationships.
• Data obtained in the course of providing services to the Client under contracts: assignment, agency, and provision of services.

3.3. Storage of Personal Data.

3.3.1. Personal data of Subjects may be received, further processed, and stored both in hard copy and electronic form.

3.3.2. Personal data recorded on paper media are stored in a fireproof cabinet under lock and key.

3.3.3. Personal data of Subjects processed using automated means for different purposes are stored in separate folders.

3.3.4. Storage and placement of documents containing personal data in open electronic directories (file sharing services) is prohibited.

3.3.5. Personal data shall be stored in a form that allows identification of the subject for no longer than required for the purposes of their processing, and they shall be destroyed upon the achievement of the processing purposes or when the need for achieving them is no longer present.

3.4. Destruction of Personal Data

3.4.1. Documents (media) containing personal data are destroyed by burning or crushing (shredding). A shredder may be used to destroy paper documents.

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2. Personal data on electronic media are destroyed by erasing or formatting the media.

3.4.3. Destruction is performed by a committee. The fact of destruction of personal data is confirmed by a media destruction report signed by the committee members.

3.5. Transfer of Personal Data

3.5.1. The Company entrusts the processing of personal data to third parties in the following cases:

• The subject has expressed consent to such actions;
• The transfer is required by Russian or other applicable legislation within the framework of the procedure established by law.

3.5.2. List of persons to whom personal data is transferred.

Third parties to whom personal data is transferred:

• The Pension Fund of the Russian Federation for accounting purposes (legally);
• Tax authorities of the Russian Federation (legally).
• Airlines transporting the personal data subject.

4. Personal Data Protection

4.1. In accordance with regulatory requirements, the Company has created a personal data protection system consisting of legal, organizational, and technical protection subsystems.

4.2. The legal protection subsystem is a set of legal, organizational, administrative, and regulatory documents ensuring the creation, operation, and improvement of the personal data protection system.

4.3. The organizational protection subsystem includes the management structure of the personal data protection system, the permitting system, information protection when working with employees, partners, and third parties, information protection in advertising activities, and analytical work.

4.4. The technical protection subsystem includes a set of technical, software, and hardware tools ensuring the protection of personal data.

4.5. The main measures to protect personal data used by the Company are:

4.5.1. Appointment of a person responsible for processing personal data, who will organize the processing of personal data, provide training and instruction, and internally monitor compliance by the Company and its employees with personal data protection requirements;

4.5.2. Identifying current threats to the security of personal data when processed in the personal data information system and developing measures and activities to protect it;

4.5.3. Developing local regulations regarding the processing of personal data;

4.5.4. Establishing rules for accessing personal data processed in the ISPD, as well as ensuring the registration and accounting of all actions performed with personal data in the personal data information system.

4.5.5. Establishing individual passwords for employee access to the information system in accordance with their job responsibilities;

4.5.6. Using information security tools that have undergone the established compliance assessment procedure;

4.5.7. Certified antivirus software with regularly updated databases;

4.5.8. Certified software to protect information from unauthorized access;

4.5.9. Compliance with conditions that ensure the safety of personal data and prevent unauthorized access;

4.5.11. Detection of unauthorized access to personal data and taking appropriate measures;

4.5.12. Restoration of personal data modified or destroyed due to unauthorized access;

4.5.13. Training of Company employees directly involved in the processing of personal data in accordance with the requirements of Russian Federation legislation regarding the protection of personal data, including documents defining the Company's policy regarding the processing of personal data and local regulations on the processing of personal data;

4.5.14. Implementation of internal control and audit.

5. Basic Rights of the Personal Data Subject and Obligations of UNI SKY LLC

5.1. Basic Rights of the Personal Data Subject:

5.1.1. The personal data subject has the right to request that UNI SKY LLC clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights.

5.1.2. The personal data subject has the right to receive information regarding the processing of their personal data, including:

1. confirmation of the fact that UNI SKY LLC is processing their personal data;
2. the legal basis and purposes for processing the personal data;
3. the purposes and methods used by the operator for processing the personal data;
4. the name and location of UNI SKY LLC, information about individuals (except for the Company's employees) who have access to personal data or to whom personal data may be disclosed under an agreement with UNI SKY LLC or under federal law;
5. the processed personal data relating to the relevant personal data subject, and the source thereof, unless another procedure for submitting such data is provided for by federal law;
6. the processing timeframes for personal data, including the storage period;
7. the procedure for the exercise by the personal data subject of the rights provided for by this Federal Law;
8. information on completed or proposed cross-border data transfer;
9. the name or last name, first name, patronymic, and address of the person processing personal data on behalf of UNI SKY LLC, if the processing has been or will be entrusted to such person;
10. other information stipulated by federal laws.

5.1.3. Contacting UNI SKY LLC and sending requests to it;

5.1.4. Appealing against the actions or inactions of UNI SKY LLC.

5.2. Responsibilities of UNI SKY LLC:

UNI SKY LLC is obligated to:

• when collecting personal data, provide the personal data subject, upon request, with information about the personal data received;
• notify the personal data subject if the personal data was not received from the personal data subject;
• if the personal data subject refuses to provide personal data, the legal consequences of such refusal are explained to the personal data subject;
• publish or otherwise ensure unrestricted access to the document defining its personal data processing policy and to information about the implemented personal data protection requirements;
• take or ensure the adoption of necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and other illegal actions in relation to personal data;
• respond to inquiries and requests from personal data subjects and their representatives regarding the protection of their rights.

6. Dispute Resolution:

6.1. Before filing a claim in court regarding disputes arising from the relationship between a personal data subject and UNI SKY LLC, it is mandatory to submit a claim (a written or electronic proposal for voluntary dispute resolution).

6.2. UNI SKY LLC will notify the Personal Data Subject of the results of its review within 30 calendar days of receiving the claim, in writing or electronically.

6.3. If no agreement is reached, the dispute will be referred for review in accordance with the current legislation of the Russian Federation.

6.4. The current legislation of the Russian Federation shall apply to this Privacy Policy and the relationship between the Personal Data Subject and UNI SKY LLC.

7. Additional Terms

7.1. UNI SKY LLC reserves the right to amend this Privacy Policy without the consent of the Personal Data Subject.

7.2. The new Privacy Policy shall take effect from the moment it is posted on the UNI SKY LLC website, unless otherwise provided in the new version of the Privacy Policy.

7.3. Any suggestions or questions regarding this Privacy Policy should be sent to: info@unisky.aero

7.4. The current Privacy Policy is available on the Website page: https://unisky.aero/en/privacy-policy/

USER AGREEMENT

The subject of this User Agreement is the relationship between UNI SKY LLC, the copyright holder of the Internet service located at https://unisky.aero/ (hereinafter referred to as the "Website"), and the terms and conditions under which the Website administration provides access to the Website's resources, including access to text and graphic materials, and the terms and conditions for Users' use of the Website's materials and services. All services provided at the time the User joins this Agreement, as well as any development and/or additions thereto, are the subject of this Agreement.

1. General Terms

User – a person who has access to the Website via the Internet and uses https://unisky.aero/ to view information, book, and purchase services. 1.1. Use of all materials and services on the Website is governed by current Russian legislation.

1.2. This Agreement is a public offer. By accessing the materials on the Website, the User agrees to accept it.

1.3. The Company reserves the right to change the terms of the Agreement; they shall take effect upon publication of the revised Agreement. Users who do not agree with the changes are obligated to cease using the materials and services on the Website.

2. User Obligations

2.1. The User agrees not to violate Russian and international laws, including those related to intellectual property, copyright and related rights, and the protection of personal honor and dignity, through their actions and comments on the Website, or to harm the operation of the Website and its services.

2.2. In accordance with Article 1270 of the Civil Code, use of materials on the Website without the consent of the Copyright Holders, as specified in the agreement, is prohibited.

2.3. When citing materials, a link to the Website is required.

3. Obligations of the Company

3.1. The Company, the owner of the Website, is not responsible for any consequences resulting from clicking on links to external resources.

3.2. The Company is not responsible for any losses or damages incurred by the User as a result of registering on the Website.

4. Other Terms

4.1. All disputes related to the Agreement will be considered by the courts in accordance with the laws in force in the Russian Federation.

4.2. The information provided on the Website cannot be considered a partnership and is for informational purposes only.

4.3. A court decision invalidating any provision of this Agreement does not invalidate it entirely.

4.4. The User confirms that they have read and accept all provisions of this Agreement.

5. Consent to the Processing of Personal Data

I hereby consent to UNI SKY LLC (TIN 9731106136, KPP 773101001, 121354, Moscow, Dorogobuzhskaya St., Building 14, Bldg. 4, Telephone: +7 495 260 60 08) processing my personal data (full name, passport series and number, contact telephone number, email address) for the purpose of fulfilling UNI SKY LLC's obligations to me as set forth in the Service Agreement and Agency Agreement for the provision of services.

UNI SKY LLC may use my consent to conduct various types of research and improve the quality of services provided, while ensuring compliance with the laws and regulations of the Russian Federation, as well as the internal charter of UNI SKY LLC.

I agree to the collection, systematization, storage, use, blocking, and deletion of my personal data in cases stipulated by current Russian legislation, carried out using specialized tools.

I am aware that all personal information about me, as a client, may be transferred to third parties (intermediaries) for the purpose of organizing the provision of services and payment for services.

I have been informed that UNI SKY LLC guarantees the security of my personal data. This consent is valid indefinitely. This consent may be revoked at any time upon my written request in accordance with the requirements of Russian legislation.