Consent to Data Processing

Effective September 8, 2026

By submitting any form on tourleader.club ("Website") — including booking requests, inquiries, or newsletter subscriptions — you confirm the following:

1. Who Processes Your Data

You consent to the processing of your personal data by:

  • Travel Club LLC (Russia, Smolensk) — the controller: trip organization and booking;
  • Egorsky LLC (Wyoming, USA) — a processor acting on the controller’s instructions: website development and operations.

2. Data We Collect

Consent covers the following data:

  • Full name;
  • Phone number;
  • Email address;
  • Messenger accounts (Telegram, WhatsApp);
  • City of residence;
  • Travel, accommodation, and equipment preferences;
  • For each traveller on a booking: surname and given name in Latin script, date of birth, sex, citizenship, and passport details;
  • Any other data you voluntarily provide through Website forms.

3. Purposes

  • Processing trip and yacht booking requests;
  • Arranging and administering a booking, including registering travellers with suppliers;
  • Communicating with you about bookings and services;
  • Sending marketing communications (with separate consent);
  • Publishing reviews (name and text only, without contact details);
  • Improving our Website and services;
  • Fulfilling obligations under the Service Agreement.

4. Processing Methods

Data is processed using automated and/or manual means, including: collection, recording, organization, storage, modification, retrieval, use, transfer, anonymization, blocking, deletion, and destruction.

5. Transfer to Suppliers, Including Abroad

5.1. To arrange a booking we pass traveller data to the suppliers who actually provide the services: liveaboard and yacht operators, hotels, dive centres, carriers, insurers, and transfer providers.

5.2. Most of these suppliers are outside the Russian Federation, so this transfer is cross-border. You consent to it. Only the data a given supplier needs is sent, and only for the booking concerned.

5.3. Data is also processed by our payment provider and by Egorsky LLC (Wyoming, USA), which operates the Website on our instructions.

5.4. All enquiries, requests and correspondence are processed with the help of artificial intelligence services, including foreign ones, acting on our instructions. You consent to this processing, including the cross-border transfer of the data contained in your enquiries.

5.5. We do not publish or otherwise disseminate your personal data, and we do not sell it.

6. Duration

6.1. This consent is effective from the moment of submission until withdrawal.

6.2. Data is processed until the purposes are fulfilled or until you withdraw consent.

7. Withdrawing Consent

7.1. You may withdraw consent at any time by emailing info@tourleader.club with the subject "Withdraw data processing consent".

7.2. We will cease processing and delete your data within 30 days, except where processing is required by law or an existing contract.

7.3. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

For more details, see our Privacy Policy.

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