This is a draft following Russian Federal Law 152-FZ, not legal advice. Have a lawyer review it. Under 152-FZ art. 18(5), personal data of Russian citizens must first be recorded in databases located in Russia; the current Cloudflare D1 database is in Europe and Telegram is abroad. Choose a compliant setup before launch.
Version of [date]
1. Who processes the data
Data controller: [operator name], tax ID [•••], address [•••]. Contact for personal data questions: [e-mail].
2. What data we receive
- Your name
- Phone, messenger handle or e-mail
- Trip preferences: dates, group, experience, boat, comments
- Technical data: page the request was sent from, referral source and UTM tags, country by IP address, a hashed IP for spam protection
- Analytics data, if analytics is enabled (cookies)
3. Why
To answer your request, suggest an expedition format, send the programme and price, agree dates and preparation, and to understand which pages of the site are useful.
4. Legal basis
Your consent, given by ticking the box in the request form. You can withdraw it by writing to the address in section 1.
5. Where and how long data is stored
Requests are stored [storage location] only as long as needed to prepare and run the trip and no longer than 3 years after the end of the trip after your last contact. Then they are deleted.
6. Who receives the data
Only the organiser and team see the data to prepare the trip. We do not sell it or share it with third parties for advertising. Technically it passes through the site hosting and the notification service listed in section 5.
7. Your rights
You can ask what data we hold about you, request correction or deletion and withdraw consent. Write to the address in section 1; we will answer within the legal time limit.
8. Cookies and analytics
If web analytics is enabled, it uses cookies to count visits and understand which content is useful. You can disable cookies in your browser settings.