here You can find short version
0) General Data Protection Policy of all Severstal Group companies
1) Who is responsible for the processing of Your Personal Data?
2) Whom can You contact?
3) What Personal Data are we processing?
4) Why do we process Your Personal Data (purpose and legal basis)?
5) Based on what other obligations do we process your data?
6) What are Your rights under data protection legislation?
7) Our Privacy Principles
8) How long are Your data stored?
9) Who receives Your data?
* Aircompany is the part of the Severstal Group and adheres to high standards in the field of data privacy, complies with the top-level policy of the Group, which is given above. However, JSC Severstal Management is not a co-controller of Aircompany and does not receive any subjects (passengers)` Personal Data from Aircompany.
LLC Severstal Aircompany, legal address: 162693, Russia, Vologodskaya obl., d. Botovo, Airport (hereinafter-“Aircompany”, “we”, “us”) being a data controller, is responsible for the processing of your Personal Data within the context of offering services via this website.
Aircompany performs services on regular domestic and international flights, charter flights inside of Russia, to CIS countries and Europe. We take all the necessary technical and organizational measures to protect Personal Data of the passengers (clients) of the Aircompany, which meet requirements of the relevant international standards and the legislation of the Russian Federation and the EU.
If you have any queries regarding data protection in connection with our website or the services offered by the Aircompany, please contact our data protection specialist:
(1) by e-mail email@example.com
(2) legal address of LLL“Aircompany "Severstal": 162693, Russia, Vologodskaya obl., d. Botovo, Airport.
We carefully and gently process your Personal Data solely to realize the possibility of providing You with the services. We process the following Personal Data:
If You left an appeal (feedback, question) on the website, by e-mail or at the official address of the Aircompany, then we process those Personal Data that You could additionally voluntarily provide at Your discretion in your appeal (letter).
If You provide to us sensitive Personal Data (information about your health or disability) in order to request special convenient conditions and support during transportation (flight), You give us explicit and free consent for processing such data. Consent will be the legal basis for processing Your sensitive Personal Data.
If You are applying for the job in LLL“Aircompany "Severstal" via website We process Your Personal Data provided in Your CV. It could be surname, name, father`s name (if any), age, education, city of living, previous work places/employers, work experience, skills and hobbies. We kindly ask You to refrain from sending us any extra, unnecessary information or any data on Your health or other sensitive data (racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership or sexual life).
We also use functionally and technically necessary Cookies, so collect information on connection IP address, connection time, duration of connection during Your session on the web-site as well as analytical Cookies. We put the notification about Cookies on the bottom of Your screen during the first visit to the website and the full version of the Cookies Policy is also here under the link.
Sources of obtaining Your Personal Data: personal data is provided both by the passenger himself or his representative by filling out the ticket purchase on the Aircompany's website or through the websites of third-party services (aggregators), as well as offline at the ticket office.
We process Your Personal Data under the provisions of the EU General Data Protection Regulation 2016/679 (GDPR) as well as the Russian Federal Law on Personal Data (No. 152-FZ). Full list of relevant legal acts could be found in next paragraph 5.
We process Your Personal Data for the performance of the contract to which You are a party or in order to take steps at Your request prior to entering into the contract under Art. 6(1) (b) of GDPR. In particular, these purposes are:
You are obliged to provide Us Your Personal Data necessary for the ticket purchase otherwise issuing of the air ticket and further providing of flight services are impossible. We process Your data for compliance with a legal obligation to which the controller is subject, for example as a carrier for:
We also process Your Personal Data for the purposes of our legitimate interests under Art. 6(1)(f) of GDPR, in particular:
We process Your PD on the base of Your Consent for the purposes:
For the purpose of contacting with You and handling Your request we process the Personal Data that You submit to our sites additionally or sent via e-mail or post mail voluntarily. We kindly ask You to refrain from sending us any extra, unnecessary information or any data on Your health or other sensitive data (racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership or sexual life).
We process Your sensitive Personal Data (information about your health or disability) in case You request for special convenient conditions and support during transportation (flight), for example, for providing a wheelchair or other special provisions. We process Your data about disability based on explicit and free consent for processing such data. Consent will be the legal basis for processing Your sensitive Personal Data (Art. 9 of GDPR).
We process passenger data on the basis of the legal obligations under Article 6(1) (c) of GDPR, which is connected with obligations under:
To ensure aviation security, Aircompany ensures the transfer of Personal Data of aircraft passengers to automated centralized databases of Personal Data on passengers under the legislation of the Russian Federation on transport security and the legislation of the Russian Federation in the field of Personal Data, during international air transportation also to the authorized bodies of foreign states under international treaties of the Russian Federation or the legislation of foreign states of departure, destination or transit in the amount stipulated by the legislation of the Russian Federation, unless otherwise established by international treaties of the Russian Federation.
Such processing is not automated processing of Personal Data. Aircompany as any carrier transfers to the automated centralized databases of Personal Data on passengers and personnel (crew) of vehicles (ACDPDP) information on passenger transportation, including Personal Data on passengers and personnel (crew) of vehicles. This information is obtained by Aircompany:
LLC "Aircompany "Severstal" notifies You of data protection rights that are guaranteed by GDPR. You have the right to:
(1) information about the processing of Your Personal Data;
(2) access to Your Personal Data - You may request to confirm whether we process Personal Data related to You and, in this case, You may request access to Personal Data about You that we process.
(3) correct Your Personal Data (rectification) - If You believe that information about You is incorrect or incomplete, You may ask us to correct Your data.
(4) withdraw consent - when we process Your Personal Data based on Your consent, You may withdraw Your consent on Your Personal Data processing at any time. Please note that withdrawal of consent shall not affect data processing that has been carried out prior to the withdrawal of consent, as well as data processing might result in a legitimate interest or obligation based on the law to proceed with Your Personal Data processing.
(5) object to processing based on legal interests - You may object to the processing of Personal Data that we process based on our legal interests. However, we shall process Your data if we have convincing reasons to proceed with data processing.
(6) erase (“to be forgotten”) the data - You may request that we delete Your Personal Data, however, not in cases, where the law requires that we store the data.
(7) restrict processing - You may limit Your Personal Data processing.
(8) data portability - You may obtain Your Personal Data in a machine-readable format and send it to another Controller (company). We shall provide a copy of the Personal Data undergoing processing. For any further copies requested by You, We may charge a reasonable fee based on administrative costs.
Under GDPR You also have the following rights:
(9) To object to any decision that significantly affects You and that has been taken solely by automated processing. The Aircompany does not process Your data automatically, in the course of decision-making Your data is always processed by a person.
(10) To exercise the above rights, please file us a written request by e-mail firstname.lastname@example.org. Generally, we shall provide an answer to Your question/request within 30 days.
Please provide the following details so that we can identify You:
Name; Postal address or E-mail address; and optionally booking code or ticket number.
If You send us a copy of your ID, please black out all other information apart from Your first and last name and address. In order to be able to process Your request, as well as for identification purposes, please note that we will use Your Personal Data under Article 6 para. 1 (c) of the GDPR.
(11) If You have a valid reason to believe that Your rights as a data subject have been violated or affected, You have the right to file a complaint with the nearest EU national data protection authority.
To comply with Your rights when processing Your Personal Data we adhere:
We declare the absence of automated decision making or profiling on the base of Your personal data.
Your Personal Data is erased as soon as it is no longer required for the purposes stated, in any way no more than 3 years:
We stop to process Your Personal Data upon Your written request, that You can submit us at any time by e-mail: email@example.com or legal address of LLС “Aircompany "Severstal": 162693, Russia, Vologodskaya obl., d. Botovo, Airport.
However, we must continue to store Your data, if it is required by compulsory applicable law, set by the legislator or supervisory authorities, which may arise from the Criminal Code of RF, Tax Code of RF or Money Laundering Law of RF, Civil Code of RF and Civil Procedure Code of RF (for example, for the purpose of exercising or defending against legal claims), etc.
LLC Severstal Aircompany processes Your data accurately and transfers it only to those persons ‘who need to know’ in order to perform services for You and observe compulsory legislation.
We may share Your Personal Data with other controllers (i.e. third parties that process Your Personal Data for their own purposes) if we are required to do so by law or court order Personal Data. Such controllers could be:
We transfer Your Personal Data in a safe way to our service providers to issue tickets. All service providers must observe Your data protection rights and apply the best technical and organizational data security measures.
We notify You, that using our web-site, booking or buying tickets You transfer Your Personal Data to Russian Federation. According to the opinion of the European Commission based on Article 45 of GDPR, it is a country that does not provide an adequate level of data protection.
If You have any further questions, do not hesitate to contact us: by e-mail firstname.lastname@example.org.
Last updated on 24.11.2022.