This Personal Data Processing Policy (the Policy) defines the procedure for the processing and protection of personal data carried out by Individual Entrepreneur Yulia Igorevna Shustrova (the Operator) in accordance with Federal Law of the Russian Federation No. 152-FZ dated July 27, 2006 “On Personal Data”.

1. General Provisions

1.1. The Operator processes personal data on a lawful and fair basis, for specific purposes determined in advance and corresponding to the Operator’s activities.

1.2. This Policy applies to all personal data received by the Operator through the website, email, contact forms, as well as in the course of interaction with agents, partners, and contractors.

1.3. Use of the website means the user’s consent to this Policy.

2. Personal Data Operator

Individual Entrepreneur: Yulia Igorevna Shustrova
Primary State Registration Number (OGRNIP): 324774600289827
Tax Identification Number (INN): 772917584749
Address: Apt. 189, Bldg. 3, 12 Akademika Anokhina St., Moscow, 119602, Russian Federation
E-mail for personal data inquiries: shustrova2000@mail.ru

3. Personal Data Processed

The Operator may process the following personal data:

• first name, last name;

• contact details (email address, phone number);

• information voluntarily provided by the user in inquiry forms (tour interests, comments);

• other information provided by the user at their own discretion.

The Operator does not collect personal data that is not related to the stated purposes of processing.

4. Purposes of Personal Data Processing

Personal data is processed for the following purposes:

• processing inquiries and requests submitted via the website;

• providing information about tourism products and services;

• preparing travel and tour proposals;

• organizing tourism programs through agents and partners;

• fulfilling contractual obligations of the Operator;

• complying with the requirements of the legislation of the Russian Federation.

5. Legal Grounds for Processing

Personal data is processed on the basis of:

• the data subject’s consent;

• the necessity to perform contracts and mandates;

• the requirements of the legislation of the Russian Federation.

6. Transfer of Personal Data to Third Parties

6.1. The Operator may transfer personal data to:

• agents, tour operators, and other contractors acting on behalf of the Operator;

• exclusively for the purposes of organizing and providing tourism services.

6.2. Personal data is transferred provided that confidentiality and the requirements of Russian personal data legislation are observed.

6.3. Cross-border transfer of personal data is carried out only if there are lawful grounds and in compliance with the requirements of the legislation of the Russian Federation.

7. Personal Data of Foreign Tourists

Personal data of tourists who are foreign citizens is processed in the course of providing tourism services and on the basis of consents obtained through authorized agents and partners.

8. Personal Data Retention Periods

Personal data is stored no longer than required to achieve the purposes of processing, or within the periods established by the legislation of the Russian Federation, but not exceeding 5 years, unless otherwise required by law or contract.

9. Rights of the Personal Data Subject

A personal data subject has the right to:

• obtain information regarding the processing of their personal data;

• request clarification, blocking, or deletion of their personal data;

• withdraw consent to the processing of personal data;

• submit inquiries regarding personal data processing to the Operator.

10. Personal Data Protection Measures

The Operator implements necessary legal, organizational, and technical measures to protect personal data against unauthorized access, loss, alteration, or disclosure.

11. Final Provisions

11.1. The Operator has the right to amend this Policy without prior notice.

11.2. The current version of the Policy is always available on the Operator’s website.

Last updated: 15/12/2025