1. General Provisions
This Privacy Policy has been prepared in accordance with the applicable legislation governing the processing of personal data and establishes the procedures for processing personal data and the measures taken to ensure its security by Egor Plylov and Pavel Pulkin (hereinafter jointly referred to as the "Operators").
1.1. The Operators consider the protection of the rights and freedoms of individuals, including the right to privacy and personal and family confidentiality, to be a fundamental principle of their activities when processing personal data.
1.2. This Privacy Policy (hereinafter referred to as the "Policy") applies to all information that the Operators may obtain about visitors to the website https://wannasurff.com/.
Note: This Policy applies where the processing of personal data is governed by the applicable laws of the Russian Federation. For individuals whose personal data is subject to the General Data Protection Regulation (GDPR), the Operators process personal data in accordance with the applicable requirements of the GDPR.
2. Definitions
For the purposes of this Policy:
Automated Processing means the processing of personal data using computer technology.
Blocking of Personal Data means the temporary suspension of the processing of personal data, except where processing is necessary to verify or update such data.
Website means the website available at https://wannasurff.com/.
Information System of Personal Data means databases containing personal data together with the technologies and technical means used to process such data.
Anonymization means actions resulting in the impossibility of identifying a specific individual without additional information.
Processing of Personal Data means any operation or set of operations performed with personal data, including collection, recording, organization, storage, updating, retrieval, use, disclosure, transfer, anonymization, blocking, deletion and destruction.
Operators means Egor Plylov and Pavel Pulkin jointly determining the purposes and methods of processing personal data.
Personal Data means any information relating directly or indirectly to an identified or identifiable individual.
User means any visitor to the Website.
Provision of Personal Data means disclosure of personal data to a specific person or group of persons.
Dissemination of Personal Data means disclosure of personal data to an unrestricted number of persons.
Cross-Border Transfer means the transfer of personal data to a foreign country, foreign authority, foreign individual or foreign legal entity.
Destruction of Personal Data means actions resulting in the irreversible destruction of personal data.
3. Rights and Obligations of the Operators
The Operators have the right to:
obtain accurate information and documents from data subjects;
continue processing personal data after consent has been withdrawn where permitted by applicable law;
independently determine appropriate measures for protecting personal data.
The Operators undertake to:
provide information regarding the processing of personal data upon request;
process personal data in accordance with applicable legislation;
respond to requests from data subjects;
make this Privacy Policy publicly available;
implement appropriate legal, organizational and technical security measures;
cease processing and delete personal data where required by law;
comply with other obligations established by applicable legislation.
4. Rights and Obligations of Data Subjects
Data subjects have the right to:
obtain information regarding the processing of their personal data;
request correction, blocking or deletion of inaccurate or unlawfully processed personal data;
withdraw consent at any time;
request termination of processing where applicable;
lodge complaints with competent supervisory authorities or courts;
exercise any other rights granted under applicable law.
Data subjects undertake to provide accurate and up-to-date personal information.
5. Principles of Personal Data Processing
The Operators process personal data:
lawfully, fairly and transparently;
only for specified and legitimate purposes;
only to the extent necessary for those purposes;
ensuring the accuracy and relevance of personal data;
retaining personal data only for as long as necessary to achieve the purposes for which it was collected or as required by law.
6. Purposes of Processing Personal Data
The Operators process personal data for the following purposes:
providing access to the Website and its services;
processing tour inquiries and bookings;
fulfilling contractual obligations;
communicating with Users and sending informational emails;
publishing trip reports, photographs and other media created during tours only where the data subject has provided separate consent for such publication;
maintaining, improving and analyzing the Website.
The Operators may process the following categories of personal data:
full name;
email address;
telephone number;
photographs taken during tours (only where separate consent has been provided);
IP address;
browser and device information;
cookie data;
other information voluntarily submitted through Website forms.
The legal bases for processing include:
contracts concluded with Users;
the User's consent;
applicable legislation.
Processing activities may include collection, recording, organization, storage, updating, retrieval, use, disclosure, transfer, anonymization, blocking, deletion, destruction and communication with Users.
7. Conditions for Processing Personal Data
Personal data is processed:
with the consent of the data subject;
where necessary for the performance or conclusion of a contract;
where necessary for the legitimate interests of the Operators, provided that such interests do not override the rights and freedoms of the data subject.
8. Collection, Storage and Transfer of Personal Data
The Operators implement appropriate technical and organizational measures to protect personal data against unauthorized access.
Personal data may be transferred to third parties only where necessary to perform contractual obligations, process payments, provide hosting services, website functionality, analytics, communication services or other services required for the operation of the Website, where required by applicable law, or where the data subject has provided consent.
Users may request correction or updating of their personal data by contacting:
wannasurfeu@gmail.com
Users may withdraw their consent at any time by sending a request to:
wannasurfeu@gmail.com
Third-party providers, including payment processors, hosting providers, analytics providers and communication service providers, process personal data in accordance with their own privacy policies. The Operators are not responsible for the actions of such third parties.
The Operators maintain the confidentiality of personal data.
Cookies and Similar Technologies
The Website may automatically collect technical information including:
IP address;
browser information;
device information;
operating system;
browsing activity;
cookies;
tracking pixels;
similar technologies.
These technologies are used to:
ensure proper Website functionality;
analyze Website traffic;
improve user experience;
enhance security;
evaluate advertising performance.
Users may disable cookies through their browser settings; however, doing so may affect certain Website functions.
9. Processing Activities
The Operators may collect, record, organize, store, update, retrieve, use, transfer, anonymize, block, delete and destroy personal data.
Processing may be carried out using automated means or without automation.
10. Cross-Border Transfers
Before carrying out cross-border transfers of personal data, the Operators comply with all applicable legal requirements.
Cross-border transfers may occur where necessary for:
organizing international tours;
accommodation bookings;
transportation arrangements;
insurance services;
payment processing;
operation of the Website.
Where such transfers occur, the Operators take reasonable steps to ensure that recipients provide an adequate level of protection for personal data or that another lawful basis for the transfer exists.
11. Confidentiality
The Operators and any persons authorized to access personal data shall not disclose or distribute personal data without the consent of the data subject unless otherwise required by applicable law.
12. Final Provisions
Users may submit questions regarding this Privacy Policy by contacting:
wannasurfeu@gmail.com
The Operators reserve the right to amend this Privacy Policy at any time. The current version shall be published on the Website.
The current version of this Privacy Policy is available at:
https://wannasurff.com/