Personal Data Processing Policy

Personal Data Processing Policy for users of the en.moskvatrip.ru website
Version of June 1, 2026.

1. General provisions
1.1. This Personal Data Processing Policy (the “Policy”) sets out the procedure for processing and protecting personal data of users of the en.moskvatrip.ru website (the “Website”).

1.2. The Policy has been developed in accordance with Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” and other regulatory legal acts of the Russian Federation on the processing and protection of personal data.

1.3. The personal data operator is LLC “Centre for Event Organization and Promotion “Pro Sobytie” (TIN 7802873242, PSRN 1147847350133) (the “Operator”).

1.4. The Policy applies to the processing of personal data of Website users when they:

• place orders;
• purchase electronic tickets;
• book tours, cruises, boat trips, vessel rentals, houseboats and other services presented on the Website;
• contact the Operator via feedback forms;
• subscribe to informational and advertising newsletters;
• use the Website.

1.5. The terms used in this Policy have the meanings set out in the Offer published on the Website, unless otherwise expressly provided by this Policy.

2. Personal data processed
2.1. The Operator may process the following categories of personal data:

• last name, first name, patronymic;
• phone number;
• email address;
• information about Passengers;
• information required for registration for a tour, boat trip, cruise, event or other service;
• information about purchased services and placed Orders;
• correspondence with the user;
• information contained in the user’s requests.

2.2. When the Website is used, the following may be processed automatically:

• IP address;
• information about the browser and device;
• information about the user’s actions on the Website;
• cookies;
• technical data obtained by web analytics services.

2.3. The Operator does not collect or store users’ bank card data. Payments are made through Payment Systems in accordance with their rules and security requirements.

2.4. The user is responsible for the accuracy of the personal data provided.

3. Purposes of personal data processing
3.1. Personal data is processed for the following purposes:

• placing and fulfilling Orders;
• selling electronic tickets;
• booking services;
• registering Passengers;
• sending electronic tickets;
• communicating with users;
• handling requests;
• processing refunds and rescheduling of services;
• complying with the requirements of the legislation of the Russian Federation;
• improving the Website;
• analysing the quality of the services provided;
• sending informational messages related to the fulfilment of Orders;
• sending advertising and marketing messages about the services offered and special offers.

3.2. Advertising and marketing messages are sent on the basis of the user’s separate consent, given in addition to placing an Order. The user may opt out of such messages at any time; opting out does not affect the processing of personal data required to fulfil placed Orders.

4. Legal grounds for processing
4.1. The Operator processes personal data on the basis of:

• Federal Law No. 152-FZ “On Personal Data”;
• other regulatory legal acts of the Russian Federation;
• the consent of the personal data subject, where such consent is required by law;
• the need to conclude and perform a contract to which the personal data subject is a party, or under which an Order is placed in the interests of the personal data subject.

4.2. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (provides, grants access to), depersonalises, blocks, deletes and destroys personal data, both with and without the use of automation tools.

5. Transfer of personal data
5.1. In order to fulfil its obligations to the user, the Operator may entrust the processing of personal data to and (or) transfer personal data to:

• Organisers;
• Carriers;
• cruise companies;
• owners of accommodation facilities;
• persons providing vessel rental services;
• other persons directly involved in providing the service ordered by the user.

5.2. Personal data is transferred only to the extent necessary to provide the relevant service.

5.3. The user may place an Order both in their own interests and in the interests of other persons. By providing personal data of third parties, the user confirms that they have legal grounds to provide such data to the Operator and guarantees compliance with the legislation of the Russian Federation.

5.4. To ensure the operation of the Website and fulfil its obligations to users, the Operator may engage third parties providing payment processing, electronic messaging, customer database management, web analytics, technical support and Website maintenance services, subject to compliance with the legislation of the Russian Federation on personal data.

5.5. The Operator may provide personal data to government authorities and other persons in the cases and in the manner provided for by the legislation of the Russian Federation.

5.6. Where the legislation of the Russian Federation requires the user’s consent to the transfer of their personal data to third parties, such consent is obtained separately, specifying the particular recipients and purposes of the transfer.

6. Use of cookies
6.1. The Website uses cookies and other similar technologies.

6.2. Cookies are used to:

• ensure the proper operation of the Website;
• save user settings;
• analyse traffic;
• make the Website more convenient to use;
• evaluate the effectiveness of advertising campaigns;
• compile Website usage statistics.

6.3. The user may restrict the use of cookies through their browser settings. Disabling certain cookies may cause some sections of the Website to work incorrectly.

6.4. By continuing to use the Website, the user consents to the use of cookies in accordance with this Policy.

7. Personal data processing and retention periods
7.1. Personal data is processed and stored for the period necessary to achieve the processing purposes set out in this Policy, unless a different period is established by the legislation of the Russian Federation.

7.2. Once the processing purposes have been achieved, or if it is no longer necessary to achieve them, personal data is destroyed or depersonalised, unless otherwise provided by the legislation of the Russian Federation.

8. Rights of the personal data subject
8.1. The user has the right to:

• receive information about the processing of their personal data;
• demand clarification, blocking or destruction of their personal data in the cases provided for by the legislation of the Russian Federation;
• withdraw consent to the processing of personal data where processing is based on such consent;
• opt out of advertising messages;
• appeal against the Operator’s actions to the authorised body for the protection of the rights of personal data subjects or in court.

8.2. Requests and enquiries regarding personal data processing should be sent to the Operator at the email address indicated on the Website.

9. Protection of personal data
9.1. The Operator takes the legal, organisational and technical measures necessary and sufficient to comply with the legislation of the Russian Federation on personal data and to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, dissemination and other unlawful actions.

9.2. Only persons who need such information to perform their job duties or fulfil obligations to users are granted access to personal data.

9.3. Personal data of citizens of the Russian Federation, including its collection, recording, systematisation, accumulation and storage, is processed using databases located in the Russian Federation.

10. Use of third-party services
10.1. To ensure the operation of the Website, the Operator may use web analytics services, CRM systems, email services, mass mailing services, payment services and other third-party information systems.

10.2. When such services are used, personal data is processed to the extent necessary for the relevant service to function and for obligations to users to be fulfilled.

11. Changes to the Policy
11.1. The Operator may amend this Policy.

11.2. A new version of the Policy takes effect from the moment it is published on the Website, unless otherwise specified in the new version.

11.3. The current version of the Policy is available at: https://en.moskvatrip.ru/policy.

12. Contact information
For questions related to the processing of personal data, the user may contact the Operator:

LLC “Centre for Event Organization and Promotion “Pro Sobytie”

Registered address: 14/3 Prosvescheniya Avenue, office 106, St. Petersburg, 194355, Russia

Actual address: 11 Malaya Morskaya Street, office 324, St. Petersburg, 191186, Russia

Email: info@moskvatrip.ru