Egor Plylov and Pavel Pulkin (hereinafter "We", "Our company", "Website") respect your privacy and are committed to protecting the personal data you provide to us. This Privacy Policy explains how we collect, use, transfer, and protect your data in accordance with the General Data Protection Regulation (GDPR).

1. Data Controllers
The co-controllers of your data are:
Egor Plylov & Pavel Pulkin
Email: wannasurfeu@gmail.com If you have any questions, please contact us using the email address above.

2. What Data We Collect
We may collect the following data:

• First name and last name
• Email address
• Phone number
• Photographs (taken during our tours and events)
• IP address
• Other information voluntarily provided by you through the forms on our website.

3. How We Use Your Data
We use your data to:

• Process your inquiries, applications, or orders.
• Publish tour reports, reviews, and marketing media on our website and official social media accounts.
• Send newsletters and marketing materials (only if you have given explicit consent).
• Improve the performance and user experience of our website.
• Comply with our legal and contractual obligations.

4. Legal Basis for Processing
We process your data based on the following legal grounds:
Consent: You have given clear consent for us to process your personal data for a specific purpose (including marketing and photo publication).
Contract: The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
Legitimate Interests: The processing is necessary for our legitimate interests, namely to improve our services, website functionality, and promote our tours.

5. Data Transfer to Third Parties
We may share your data with the following categories of third parties:

• Service providers (e.g., payment gateways, hosting providers).
• Marketing or analytics companies (e.g., Google Analytics). We ensure that all third parties respect the security of your personal data and treat it in accordance with GDPR requirements.

6. International Data Transfers (Outside the EEA)
If your personal data is transferred outside the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Using specific Standard Contractual Clauses (SCCs) approved by the European Commission.
• Ensuring providers in the US are certified under the EU-US Data Privacy Framework (DPF).

7. Data Retention Period
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After this period, your data will be securely deleted or anonymized.

8. Your Rights Under GDPR
Under certain circumstances, you have rights under data protection laws in relation to your personal data:

The right to access – You have the right to request copies of your personal data.
The right to rectification – You have the right to request that we correct any information you believe is inaccurate.
The right to erasure (“the right to be forgotten”) – You have the right to request that we erase your personal data or remove your photographs from our public resources.
The right to restrict processing – You have the right to request that we restrict the processing of your personal data.
The right to data portability – You have the right to request that we transfer the data we have collected to another organization.
The right to withdraw consent – You can withdraw your consent at any time where we are relying on consent to process your data.
The right to lodge a complaint – You have the right to file a complaint with a supervisory authority in your country. To exercise any of these rights, please contact us directly at: wannasurfeu@gmail.com.

9. Data Security
We have put in place appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. This includes using SSL encryption for data transmission and controlling access to our database.

10. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes.

11. Contact Us
If you have any questions about this Privacy Policy, please contact us at: wannasurfeu@gmail.com.