Privacy Policy

1. Introduction

1.1. This Privacy Policy ("Policy") describes how Tour Leader Club ("we", "us", "our") collects, uses, and protects personal data of users of tourleader.club ("Website").

1.2. The Website is operated by:

• Travel Club LLC (Russia, Smolensk) — trip organization and booking;
• Egorsky LLC (Wyoming, USA) — website development and technical operations.

1.3. We are committed to protecting your privacy in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) where applicable, and the California Consumer Privacy Act (CCPA).

1.4. By using the Website, you agree to the terms of this Policy. If you do not agree, please discontinue use of the Website.

2. Information We Collect

2.1. We may collect the following personal data:

When booking a trip or yacht:

• Name;
• Contact details (phone number, Telegram, WhatsApp — at your choice);
• City of residence;
• Accommodation, date, and equipment preferences.

When subscribing to our newsletter:

• Email address.

When submitting a review or inquiry:

• Name;
• Email address;
• Message content.

2.2. We do not collect sensitive personal data (racial or ethnic origin, political opinions, health data, etc.).

3. How We Use Your Data

3.1. We process personal data for the following purposes:

• Processing trip and yacht booking requests;
• Communicating with you about bookings and services;
• Sending marketing communications (with your consent);
• Publishing reviews (name and review text only, without contact details);
• Improving our Website and services;
• Fulfilling our obligations under the service agreement.

4. Legal Basis for Processing

4.1. We process your data based on:

• Your consent;
• Performance of a contract (when you make a booking);
• Our legitimate interests (improving services, preventing fraud);
• Compliance with legal obligations.

5. Sharing Your Data

5.1. We may share your data with:

• Travel partners (local operators, yacht operators, carriers) — to the extent necessary for service delivery;
• Payment processors — for payment processing;
• Government authorities — when required by law.

5.2. We do not sell your personal data to third parties for marketing purposes.

5.3. Your data may be transferred internationally in connection with organizing travel. We ensure appropriate safeguards are in place for such transfers.

6. Cookies

6.1. The Website uses cookies for functionality, analytics, and service improvement.

6.2. You can disable cookies in your browser settings. Disabling cookies may limit Website functionality.

7. Data Retention and Security

7.1. We retain personal data for as long as necessary to fulfill the purposes described in this Policy, or as required by law.

7.2. Upon request or when data is no longer needed, we will delete your personal data within 30 days.

7.3. We implement appropriate technical and organizational measures to protect your data against unauthorized access, alteration, or destruction.

8. Your Rights

8.1. You have the right to:

• Access your personal data and receive a copy;
• Rectify inaccurate data;
• Request deletion of your data ("right to be forgotten");
• Restrict or object to processing;
• Data portability;
• Withdraw consent at any time;
• Opt out of marketing communications.

8.2. To exercise your rights, contact us at info@tourleader.club.

8.3. We will respond to your request within 30 days.

8.4. If you are in the EU, you have the right to lodge a complaint with your local data protection authority.

9. Contact Us

For any questions about this Privacy Policy or your personal data: