PRIVACY POLICY

and Personal Data Processing

1. GENERAL PROVISIONS

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

The personal data controller is NEW WAVE TRVL CO., LTD., registration number 0835566026241, registered address: 59/45 4 Road, 83120, Kingdom of Thailand, telephone: +66 61 271-44-77, email: e-mail@newwave.travel (hereinafter referred to as the Operator).

The Operator processes personal data in compliance with the principles of lawfulness, fairness, and data minimization, ensuring the protection of the rights and freedoms of personal data subjects. This Policy applies to all information that the Operator may receive about users when requesting the Company's services.

2. BASIC TERMS

This Policy uses terms with the meaning established by Federal Law No. 152-FZ "On Personal Data," including:

– personal data;

– operator;

– personal data processing;

– automated processing;

– blocking;

– depersonalization;

– destruction;

– cross-border transfer;

– the subject of personal data.

3. PERSONAL DATA PROCESSED BY THE OPERATOR

The Operator may process the following personal data:

– last name, first name, patronymic;

– date of birth;

– identity document details (series, number, expiration date, citizenship) — for the purpose of arranging travel services and visas;

– email address;

– telephone number;

– other data voluntarily provided by the subject when submitting an application. The Operator does not process special categories of personal data as provided for in Article 10 of Federal Law No. 152-FZ, except in cases expressly provided for by Russian Federation law.

4. PURPOSES OF PERSONAL DATA PROCESSING

Personal data is processed for the following purposes:

– Concluding, executing, and terminating civil contracts;

– Processing applications for travel services;

– Processing visas and other permits;

– Sending informational and service notifications;

– Complying with Russian Federation law.

The data subject has the right to opt out of receiving informational messages by sending an email to @newwave.travel with the subject "Opt-out of notifications."

5. LEGAL BASIS FOR PROCESSING

The Operator processes personal data based on:

– Federal Law No. 152-FZ;

– Federal Law No. 149-FZ "On Information, Information Technology, and Information Protection";

– The Civil Code of the Russian Federation;

– Other regulatory acts of the Russian Federation;

– Agreements concluded with personal data subjects;

– Consent of the personal data subject.

6. PROCESSING PRINCIPLES

Personal data is processed:

– Lawfully and fairly;

– Only for predetermined and legitimate purposes;

– Without merging databases with incompatible purposes;

– To the extent necessary and sufficient to achieve the purposes;

– Ensuring the accuracy and relevance of the data;

– No longer than the period necessary to achieve the processing purposes.

7. PROCESSING AND STORAGE TERMS

Personal data is processed:

– With the consent of the personal data subject;

– As part of the performance of the agreement;

– In cases stipulated by the legislation of the Russian Federation.

The storage period is determined by the achievement of the processing purposes or the requirements of the law. Personal data is destroyed or anonymized once the processing purposes have been achieved or upon withdrawal of consent, unless otherwise provided by law.

8. RIGHTS OF PERSONAL DATA SUBJECTS

A personal data subject has the right to:

– receive information about the processing of their data;

– request clarification, blocking, or destruction of data;

– revoke consent to processing;

– appeal the Operator's actions to Roskomnadzor or in court.

Requests should be sent to: e-mail@newwave.travel or by phone: +66 61 271-44-77.

9. TRANSFER OF PERSONAL DATA

Personal data is not transferred to third parties, except for:

– cases stipulated by Russian Federation law;

– fulfillment of contractual obligations (air carriers, hotels, visa centers, insurance companies);

– the consent of the personal data subject. The Operator has the right to transfer data to payment systems, hosting providers, and other contractors involved in the provision of services, provided they comply with the requirements of personal data protection legislation.

10. CROSS-BORDER TRANSFER

Cross-border transfer of personal data is carried out only in compliance with the requirements of Russian Federation legislation and with the necessary guarantees to protect the rights of personal data subjects.

11. PERSONAL DATA PROTECTION MEASURES

The Operator takes legal, organizational, and technical measures, including:

– Restricting access to personal data;

– Using secure data transmission channels;

– Internal processing regulations;

– Monitoring and auditing personal data processing.

12. FINAL PROVISIONS

This Policy is valid indefinitely until a new version is adopted. The Operator reserves the right to amend the Policy; the current version is communicated to personal data subjects.

All questions related to the processing of personal data should be sent to: e-mail@newwave.travel or by phone: +66 61 271-44-77.

OPERATOR DETAILS

Name: NEW WAVE TRVL CO., LTD.

Registration number: 0835566026241

Legal address: 59/45 หมู่ 4 ตำบลกะทู้ อำเภอกะทู้ จังหวัดภูเก็ต 83120, Kingdom of Thailand

Phone: +66 61 271-44-77

E-mail: e-mail@newwave.travel

Director: นางสาวโสภิตา ผลเจริญ (Losgitta Palcharoen)