PRIVACY STATEMENT, COOKIE & GDPR POLICY

I. Scope of this Privacy Statement

This Privacy Statement describes the types of personal information ExploRussia (“Company,” “us,” “we” or “our”) collects through www.explorussia.com (collectively, the “Site”), and how we collect, use, and share that information. This Privacy Statement does not govern our collection of personal information through any website or other means, other than through the Site.

By using the Site, you explicitly accept, without limitation or qualification, our practices surrounding the collection, use, and sharing of personal information provided by you in the manner described in this Privacy Statement. If you do not agree to the terms of this Privacy Statement, please do not access, browse, or use the Site.

II. Personal Information We Collect

A. Information You Give Us

You do not have to give us any personal information to browse the Site. However, you may be asked to provide personal information to submit or request information from us, or to use the services offered through the Site. Upon request form(s), we collect information such as your name, country, e-mail address, and telephone number, and any other information you provide us. Once you provide us with personal information about you, you are no longer anonymous to us.

B. Automated Information Collection

We may collect certain information about your use of the Site through the use of tracking technologies or by other passive means. This “passively collected” information includes, but is not limited to, the domain name of the website that allowed you to navigate to the Site, search engines used, the internet protocol (IP) address used, the length of time spent on the Site, the pages you looked at on the Site, other websites you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:

• Log Information. When you access the Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser.
• Links.The Site may include links in a format that enables us to keep track of whether these links have been followed by IP addresses. We use this information to improve the quality of our products and design.
• Cookies. When you visit or access the Site, we send one or more cookies (small text files containing a string of characters) to your computer that uniquely identifies your browser. We use cookies to improve the quality of the Site by storing user preferences and tracking user trends. Most web browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may not be able to use some customized features available through the Site.
• Web Beacons. Web beacons (also known as “pixel tags” or “clear GIFs”) are 1×1 single-pixel graphics that allow us to count the number of users who have visited or accessed the Site and to recognize users by accessing our cookies. We may employ web beacons to facilitate Site administration and navigation, to track the actions of users of the Site, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for visitors to the Site. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened.
• Do Not Track. We do not respond to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about an individual consumer’s online activities over time and across third-party websites or online services.
• Third Party Tracking. To deliver you the best service we use Google (https://gsuite.google.com/terms/dpa_terms.html), Facebook (https://www.facebook.com/about/privacy/) and WordPress (https://automattic.com/privacy/) tools.

III. How We Use Personal Information

Personal information collected through the Site may be used by Company and its affiliates for purposes of:

• Creating and storing a user profile for you;
• To fulfill service requests;
• To notify you regarding the status of service requests;
• Sending you marketing materials;
• Responding to your questions;
• Contacting you, whether by email, postal mail, or telephone with information about the Site or our services;
• For such purposes as you may authorize at the time you submit the information;
• Auditing, research, and analysis to maintain, protect, and improve the Site and our services;
• Ensuring the technical functions of our network;
• Improving and customizing the content and layout of the Site;
• Developing new products and services; or
• Compiling personal information and other information collected through the Site on an aggregate basis.

IV. Personal Information We Share

We do not sell, rent, trade, or otherwise share personal information collected through the Site, except as described below:

• Subsidiaries and Affiliates. We may share personal information with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes.
• Service Providers. We work with third parties that provide services on our behalf. Such services may include third party travel, booking and related technology services, mobile telecommunications providers, expense management services, website hosting, marketing, and website usage analytics. We may share personal information and non-personal information with these third parties for the purpose of enabling them to provide these services.
• To procure products and services for you. In order to procure products and services specifically requested by you from third parties as part of our corporate travel, event planning and leisure services, we may provide, as necessary, your personal information, such as your name, email address, telephone, credit card information and personal preferences (such as seating preferences), and other personal information required by the TSA, IATA to such third parties just as you or your assistant would if you directly procured those products and services yourself. We share this information only as necessary and required to process your procurement request on your behalf. As an example, if you wanted to book or change a flight using our travel services, we would share with the airline or travel booking agency your name, phone number, billing address, and credit card information as well as any other required information. We may also share personal information with our customer, in connection with our corporate travel, event planning and leisure services. Please note that we do not take any responsibility for use or disclosure of any such information by these product and service providers (such as airlines, hotels, or rental car companies) or your employer, whose use of such information is governed by their own separate privacy policies. If you are concerned about the manner in which these product and service providers use or disclose your personal information, you should review their privacy policies prior to such use.
• Consent. We may share personal information in accordance with any consent you provide.
• Required by Law. We may disclose personal information or any information collected through the Site if we are required to do so by law or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.
• Certain Transactions. We may disclose or transfer personal information or any information collected through the Site to third parties who acquire all or a portion of Company’s business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

V. Aggregate Information

We may compile personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of users who have registered for the Site, demographic information about users of the Site, and individual purchase preferences. Such aggregate information does not identify you individually. We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Statement, and for any other lawful purpose.

VI. Your Choices

A. Information You Provide

You can always choose whether or not to provide information on the Site. However, if you choose not to disclose certain information, you may not be able to register as a user of the Site, which may limit your access to certain portions of the Site or our services.

B. Communications From Us

If at any time you decide that you no longer wish to receive notices from us regarding the Site, you may indicate this preference by contacting us at welcome@explorussia.com

VII. Information Storage and Security

We employ reasonable security precautions to protect personal information about you. The Site is operated from an environment with integrated security measures to help protect against the loss, misuse, and alteration of personal information provided on or through the Site. These security measures include Secure Socket Layer (SSL) technology data transmission. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.

VIII. A Special Note about Children

Children are not eligible to use the Site, and we ask that minors (children under the age of 16) not submit any personal information to us. If you are a minor, you can use the Site only in conjunction with your parents or guardians.

IX. External Links

The Site may contain links to various websites that Company does not control. When you click on one of these links, you will no longer be transacting business through the Site. Third party websites maintain their own privacy policies, and we do not exercise any control over any of the third party websites that may be linked to the Site. If you visit a website that is linked to the Site, you should consult that website’s privacy policy before providing any personal information. Please be aware that we are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of personal information about you.

X. Updates to this Privacy Statement

We may change or update the Site or any of our policies and procedures without prior notice. Your continued use of the Site signifies your continued assent to the terms of this Privacy Statement, as updated or amended at that time.

XII. Questions Regarding this Privacy Statement

If you have any questions or comments regarding this Privacy Statement, please send us an email at welcome@explorussia.com

This Privacy Policy is effective as of May 24, 2018.

EXPLORUSSIA GDPR PRIVACY NOTICE

General Data Protection Regulation (GDPR)

Article 13 of Regulation EU 2016/679

1. Purpose of this notice

This Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing. Definitions of certain terms within this notice are explained in the appendix.

2. The Data Controller for personal data

The Data Controller for the personal data processed by us is the User (also User and members of its family or any other travellers who travel with or without User hereafter referred to as the Data Subject). The Data Controller will pass personal data of travellers to ExploRussia to manage travel on behalf of those travellers in connection with User. ExploRussia, as Data Processor acting on the instructions of the Data Controller under Terms and Conditions, Privacy Policy, will subsequently use that personal data to facilitate travel arrangements for the Data Subject.

ExploRussia will also become a Data Controller if it collects additional personal data directly from a Data Subject. ExploRussia also acts as a Data Controller for any personal data held regarding its own employees, and legally processes this data under its Contract of Employment with those Data Subjects.

3. Your Rights

As a Data Subject you have rights under the GDPR. These rights can be seen below. ExploRussia will always fully respect your rights regarding the processing of your personal data, and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.

4. Contact Details

The identity and contact detail for the Data Protection Officer within ExploRussia is:

Ruslan Bets, Chief Technology Officer

Explore Partners LLC

652882, Russia, Kemerovo district, Mezhdurechensk, Gastello, 76.

5. Data Protection Principles

ExploRussia has adopted the following principles to govern its collection and processing of Personal Data:

• Personal Data shall be processed lawfully, fairly, and in a transparent manner.
• The Personal Data collected will only be those specifically required to fulfill travel, accommodation, or other travel-related requirements.
• Personal Data shall only be retained for as long as it is required to fulfil contractual requirements.
• Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date.
• The Data Subject has the right to request from ExploRussia access to and rectification or erasure of their personal data, to object to or request restriction of processing concerning the data, or to the right to data portability. In each case such a request must be put in writing as in Section 3 above.

The Data Subject has the right to make a complaint directly to a supervisory authority within their own country. ExploRussia’s Data Protection compliance is supervised by:

Ruslan Bets, Chief Technology Officer

Explore Partners LLC

652882, Russia, Kemerovo district, Mezhdurechensk, Gastello, 76.

• Personal Data shall only be processed based on the legal basis explained in section 2 above, except where such interests are overridden by the fundamental rights and freedoms of the Data Subject which will always take precedent. If the Data Subject has provided specific additional Consent to the processing, then such consent may be withdrawn at any time (but may then result in an inability to fulfil travel requirements).
• ExploRussia will not use personal data for any monitoring or profiling activity or process, and will not adopt any automated decision making processes.

6. Transfers to Third Parties

To fulfil the travel arrangements for a Data Subject it will in most cases be necessary to process personal data via a third party (these will include but are not limited to airlines, hotels, car hire companies, and Visa or Passport companies). Personal Data shall only be transferred to, or processed by, third party companies where such companies are necessary for the fulfilment of the travel arrangements.

Personal Data shall not be transferred to a country or territory outside the European Economic Area (EEA) unless the transfer is made to a country or territory recognised by the EU as having an adequate level of Data Security, or is made with the consent of the Data Subject, or is made to satisfy the Legitimate Interest of ExploRussia in regard to its contractual arrangements with its clients.

Appendix – Definitions of certain terms referred to above:

Personal Data:

(Article 4 of the GDPR): ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing:

(Article 4 of the GDPR): means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction.

Legal Basis for Processing:

(Article 6 of the GDPR): At least one of these must apply whenever personal data is processed:

1. Consent: the individual has given clear consent for the processing of their personal data for a specific purpose.
2. Contract: the processing is necessary for compliance with a contract.
3. Legal obligation: the processing is necessary to comply with the law (not including contractual obligations).
4. Vital interests: the processing is necessary to protect someone’s life.
5. Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law.
6. Legitimate interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

Data Controller:

(Article 4 of the GDPR): this means the person or company that determines the purposes and the means of processing personal data.

Data Processor:

(Article 4 of the GDPR): means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.

Data Subject Rights:

(Chapter 3 of the GDPR) each Data Subject has eight rights. These are:

1. The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
2. The right of access; this is your right to see what data is held about you by a Data Controller.
3. The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
4. The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
5. The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
6. The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
7. The right to object; the Data Subject has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
8. Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.