Personal Data Processing Policy

Revision dated 3 июля 2026

This is an informational English translation. In case of any discrepancy, the Russian version prevails.

1. Personal Data Operator

ИП Шурубару Алексей Викторович, INN 920459335129, OGRNIP 320920400013667 (hereinafter — the Operator). Contacts: info@tour-sailing.com, +7 900 055 8925. For personal data matters: info@tour-sailing.com.

This Policy defines the procedure for processing and protecting personal data and has been developed in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter — the Law).

2. Legal Grounds

Processing is carried out on the basis of: the consent of the personal data subject (Art. 6, Part 1, Clause 1 of the Law), provided as a separate document; the performance of a contract to which the subject is a party (Art. 6, Part 1, Clause 5); as well as for the purposes provided for by the Law.

3. Purposes of Processing

Receiving and processing enquiries submitted through the website; contacting the applicant, selecting and confirming available tour dates; concluding and performing a service contract; responding to enquiries; where separate consent is given — sending informational and marketing messages; maintaining anonymised website visit statistics.

4. Categories of Subjects

Website visitors who have completed the enquiry form; tour customers and guests; persons who have contacted the Operator using the details provided.

5. List of Personal Data Processed

Name; phone and/or messenger number; email address; information voluntarily provided in the comment field (desired tour, dates, number of guests). Automatically, when using the website — anonymised visit data (cookies, IP address, browser type) — only where analytics are enabled and you have consented to cookies (see Section 12). The Operator does not process special categories of data or biometric data.

6. Methods and Retention Periods

Processing is carried out with and without the use of automation. Enquiry data is stored no longer than necessary for the purposes of processing, and where a contract is concluded — for the period established by law; in all other cases — until consent is withdrawn. Anonymised analytics data is stored for the period established by the relevant analytics service.

7. Destruction Procedure

Upon achievement of the processing purposes, withdrawal of consent, or a justified request from the subject, personal data is subject to destruction (or anonymisation) within the period established by the Law. The Operator notifies the subject of such destruction upon request.

8. Persons Entrusted with Processing

For the stated purposes, the Operator uses the following services (processors), each solely within the scope of the assignment:

• EspoCRM — recording and processing of enquiries (primary storage — on a server located in the Russian Federation);
• Telegram Messenger — prompt notification of the Operator about a new enquiry;
• Email service — delivery of enquiry notifications to the Operator's mailbox;
• Hosting provider — hosting of the website and databases.

Data is not sold or transferred to third parties for their own purposes.

9. Cross-Border Transfer

Some notifications (messenger, email) may be processed on servers located outside the Russian Federation. Such cross-border transfer is carried out in compliance with the requirements of Art. 12 of the Law, including after notification of Roskomnadzor. The initial collection and storage of personal data of citizens of the Russian Federation is carried out in databases located within the territory of the Russian Federation (Art. 18, Part 5, of the Law).

10. Protective Measures

The Operator takes legal, organisational, and technical measures to protect personal data against unauthorised access, alteration, disclosure, or destruction: channel encryption (HTTPS/TLS), access control, protection against spam and automated requests, backups, and limiting the number of persons with access to the data.

11. Rights of the Personal Data Subject

You have the right (Art. 14 of the Law) to: obtain information about the processing of your data; require its clarification, blocking, or destruction where it is incomplete, outdated, inaccurate, or unlawfully processed; withdraw consent; and appeal the Operator's actions to Roskomnadzor or in court.

12. Cookies and Analytics

The website uses technically necessary cookies (for correct operation) — without them the website does not function. Analytics and marketing cookies are enabled only after your consent in the cookie banner; analytics do not run before consent is given. You may withdraw consent by clearing cookies in your browser or changing your choice in the banner.

13. Personal Data Enquiries

Send requests, consent withdrawals, and other enquiries to info@tour-sailing.com. A response is provided within the period established by the Law.

14. Changes

The Operator may amend this Policy. The current revision is always published on this page.