Policy on personal data processing
1. General Provisions
1.1. The personal data operator is the legal entity (details below) responsible for collecting, processing, and transmitting the personal data of gettsleep.com website users for the purpose of online hotel booking.
1.2. The operator acts under agency agreements with hotel owners and transfers data only to fulfill booking requests.
1.3. Data processing is carried out on Russian cloud servers of VK Cloud, protected by information security tools, and using the 1C-Bitrix CMS.
2. Personal Data and Processing Purposes
2.1. The following personal data are processed:
- First Name
- Last Name
- Phone Number
- E-mail Address
2.2. Processing purposes:
- Fulfilling booking requests
- Agency support of the transaction
- Communication regarding the booking
3. Data Transfer to Third Parties
3.1. Data (first name, last name, phone number, e-mail) are transferred to the owners of the selected hotels exclusively to fulfill the booking.
3.2. Hotel owners are separate personal data operators and store and process data according to their own policies and retention periods.
3.3. A list of legal entity partners is provided upon user request.
4. Data Retention and Deletion Periods
4.1. Data are stored by the operator on the website for three months from the date of booking.
4.2. After the specified period, data are automatically and permanently deleted from the database.
5. Use of Cookies and Analytics Services
5.1. The Yandex.Metrica service is used to collect website performance statistics and uses cookies.
5.2. Cookies may contain anonymized technical information about user visits and actions on the website (navigation paths, IP, browser, device, etc.).
5.3. Cookie processing is conducted in accordance with the user’s browser settings and policy. The user may change browser settings or refuse cookies, but this may affect the proper functioning of certain website features.
5.4. Anonymized statistical data are used only for analytics and are not transferred to third parties, except for Yandex.Metrica.
6. Consent Form
6.1. Before submitting a booking request, the user separately and explicitly (via a separate checkbox) confirms consent to the processing and transfer of personal data in accordance with this Policy, with the option to download or view the consent text.
6.2. The fact of providing consent, along with the session identifier, date, and current version of the document, is recorded in the website database and deleted along with the user data after the three-month retention period.
7. Technical and Organizational Measures
7.1. The operator uses antivirus solutions, encryption tools, DLP, and other information security means included in the VK Cloud and 1C-Bitrix platforms.
7.2. Only trained employees have access to the data, and their actions are recorded by audit systems.
8. User Rights
8.1. The user has the right to clarify, delete their data, or withdraw consent before the three-month period ends by sending a request to privacy@gettsleep.com.
8.2. After the retention period expires, the operator does not store, process, or have the technical ability to provide previously submitted data.
9. Use of Anonymized Data
9.1. The operator may use anonymized data to improve service quality without transferring them to third parties, except for analytics services.
10. Final Provisions
10.1. This Policy’s current version is effective from 15.10.2025. The operator informs users of significant changes to this Policy.
10.2. Hotel owners, as legal entities, determine their own procedures and retention periods for personal data transferred to them.
11. Personal Data Operator Details
Operator: Comfort Management Group LLC
OGRN: 1197746296428
INN: 9725009470
KPP: 504701001
Legal Address: 141425, Moscow Region, Khimki Urban District, Khimki, Sheremetyevo International Airport, Building E2, Room 3
E-mail for Inquiries: privacy@gettsleep.com