On this page
- 1. General provisions
- 2. Terms and abbreviations
- 3. Principles of personal data processing
- 4. Purposes of personal data processing
- 5. Legal grounds for processing
- 6. Categories of subjects and personal data
- 7. Consent of the personal data subject
- 8. Procedure and conditions for processing
- 9. Personal data security measures
- 10. Rights of personal data subjects
- 11. Cross-border transfers
- 12. Destruction of personal data
- 13. Liability
- 14. Contact information
- 15. Final provisions
Personal Data Processing Policy of Visit Teriberka LLC.
Visit Teriberka Limited Liability Company (Visit Teriberka LLC)
Murmansk
Revision dated 13 October 2025
1. General provisions
1.1. This Policy of Visit Teriberka Limited Liability Company (hereinafter the Operator or Visit Teriberka LLC) has been developed to meet the requirements of paragraph 2 of part 1 of Article 18.1 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (hereinafter the Law), to protect human and civil rights and freedoms when processing personal data, including the rights to privacy and personal and family confidentiality.
1.2. This Policy applies to all personal data processed by Visit Teriberka LLC.
1.3. This Policy covers all types of personal data processing, including the data of customers, employees, counterparties and users of https://visit-teriberka.com.
1.4. This Policy is publicly available online at https://visit-teriberka.com/privacy.
1.5. Operator’s address and contact details:
Apartment 28, 3 Komsomolskaya Street, Murmansk, 183038, Russia
Email: info@visit-teriberka.com
2. Terms and abbreviations
| Term | Definition |
|---|---|
| Law (152-FZ) | Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”. |
| Operator | Visit Teriberka LLC, which independently or jointly with others organises and/or carries out personal data processing and determines its purposes, the data to be processed and the actions (operations) performed on it. |
| Personal data subject | The individual to whom personal data relates. |
| Personal data (PD) | Any information relating directly or indirectly to an identified or identifiable individual. |
| Special categories of PD | Data concerning racial and ethnic origin, political views, religious or philosophical beliefs, health or intimate life. |
| Biometric PD | Information about a person’s physiological and biological characteristics (such as a facial image) that enables their identification. |
| PD authorised by the subject for dissemination | Personal data to which the subject grants access to an unlimited number of persons through separate consent under the procedure established by Roskomnadzor Order No. 18 of 24 February 2021. |
| PD processing | Any action or set of actions involving PD, with or without automated means, including collection, recording, organisation, accumulation, storage, clarification, use, transfer, dissemination, depersonalisation, blocking, deletion and destruction. |
| Automated processing | Processing PD using computing equipment. |
| Non-automated processing | Processing PD without computing equipment (on paper). |
| Provision of PD | Disclosure of PD to a specific person or group of persons. |
| Dissemination of PD | Disclosure of PD to an indefinite group of persons, including publication online. |
| Personal data information system (ISPDn) | The combination of PD and the technical means used to process it. |
| Blocking of PD | Temporary suspension of PD processing. |
| Depersonalisation of PD | Actions making it impossible to attribute data to a specific subject without additional information. |
| Destruction of PD | Actions resulting in the destruction of data and/or its media without the possibility of recovery. |
| Confidentiality of PD | The mandatory requirement not to disclose PD to third parties without the subject’s consent. |
| Cross-border transfer | Transfer of PD outside the Russian Federation. |
| PD localisation | The obligation to store and process Russian citizens’ PD within the Russian Federation. |
| Security incident (leak) | Unauthorised access to, alteration, blocking or destruction of PD. |
| PD subject’s consent | A freely given, specific and informed expression of willingness to have PD processed, in any form that allows the receipt of consent to be confirmed. |
| Cookies | Pieces of data stored on the user’s device that are necessary to identify a session and analyse use of the Website. |
| Analytics and marketing services | Web analytics services (such as Yandex.Metrica, VK Pixel and top.mail.ru) used to analyse user behaviour and improve service quality. |
| Website | The resource https://visit-teriberka.com, including all its subdomains and pages. |
| User | Any person visiting the Website and/or completing forms on it. |
| Customer | An individual who has placed or is placing an order for the Operator’s tourism services. |
| Counterparty | A legal entity or individual in a civil-law relationship with the Operator. |
3. Principles of personal data processing
3.1. Personal data is processed lawfully and fairly.
3.2. Processing is limited to achieving specific, predetermined and lawful purposes.
3.3. Databases processed for incompatible purposes must not be combined.
3.4. The content and volume of personal data correspond to the purposes of processing; excessive data is excluded.
3.5. Personal data is retained no longer than required by the purposes of processing, unless federal law provides otherwise.
4. Purposes of personal data processing
Visit Teriberka LLC processes personal data for the following purposes:
- concluding and performing tourism service agreements, including tour bookings and payments;
- communicating with Website users and customers, including responding to enquiries and clarifying requests;
- sending notifications, special offers and marketing messages with the subject’s consent;
- selecting personalised programmes and routes;
- analysing Website user behaviour, collecting statistics and optimising the service using Yandex.Metrica, VK Pixel and top.mail.ru;
- publishing customer reviews, photographs and videos based on separate consent to disseminate personal data;
- fulfilling obligations under Russian tax, accounting and labour legislation;
- maintaining personnel records and recruiting staff;
- protecting property, controlling access and ensuring information security.
| No. | Purpose | Categories of subjects | Personal data | PD processing period |
|---|---|---|---|---|
| 1 | Concluding and performing tourism service agreements, including tour bookings, payment, and issuing vouchers and tour documents | Customers, tourists | Full name, date of birth, phone number, email, passport details, order data, payment information, contact persons | For the agreement’s duration plus 3 years (limitation period); certain financial documents: 5 years (Russian Tax Code) |
| 2 | Communication and advice about tours and excursions | Website users, customers | Full name, phone number, email, city of residence, enquiry text | Up to 5 years from the enquiry or until consent is withdrawn |
| 3 | Registering requests, bookings and enquiries on the Website | Website users | Full name, phone number, email, IP address, cookies, referral source | Up to 5 years or until consent is withdrawn, where there is no contractual relationship |
| 4 | Sending notifications, promotions and offers | Mailing list subscribers, customers | Full name, email, phone number | Until consent is withdrawn or the communication channel ceases to operate |
| 5 | Publishing tour participants’ reviews, photographs and videos | Customers providing materials | Full name, image, text, audio/video | Until consent is withdrawn or the material is removed on request |
| 6 | Accounting and tax records | Customers, counterparties, employees | Full name, INN, address, payment details, income information | 5 years for primary documents; up to 10 years for accounting and tax reports |
| 7 | Personnel administration and recruitment | Employees, applicants | Full name, passport details, individual pension insurance number (SNILS), INN, education, work experience, contacts, photograph | Up to 50 years for personnel documents; applicants’ CVs: 1 year after refusal of employment |
| 8 | Website traffic analysis, service improvement and advertising targeting | Website visitors | IP address, cookies, Website behaviour, traffic sources | Up to 2 years or until cookies are cleared or consent is withdrawn |
| 9 | Information and property security | Employees, office visitors | Full name, video recording, phone number for access passes | Video recordings: up to 30 days; visitor logs: up to 1 year |
| 10 | Fulfilling obligations under Russian law | All PD subjects | Data required by regulations, including passport details, INN, agreements and certificates | Within statutory retention periods, up to 10 years |
| 11 | Communication with counterparties (partners and suppliers) | Counterparty representatives | Full name, position, business contacts (phone number, email) | Agreement duration plus 3 years (general limitation period) |
| 12 | Use of web analytics tools (Yandex.Metrica, VK Pixel, top.mail.ru) | Website users | Cookies, IP address, browser parameters, visited pages | Up to 2 years or until the user deletes cookies |
5. Legal grounds for processing
- the Constitution of the Russian Federation;
- the Labour, Civil and Tax Codes of the Russian Federation;
- Federal Law No. 152-FZ “On Personal Data”;
- other federal laws and subordinate regulations;
- the charter of Visit Teriberka LLC;
- agreements concluded with personal data subjects;
- the consent of personal data subjects.
6. Categories of subjects and personal data
6.1. Website users: full name, phone number, email, IP address, cookies and Website activity data.
6.2. Customers and clients: full name, date of birth, passport details, address, phone number, email, booking and payment information.
6.3. Employees and applicants: personal data required by labour legislation (full name, passport details, SNILS, INN, education, work experience and photograph).
6.4. Counterparties and their representatives: full name, position, contact details and business correspondence.
7. Consent of the personal data subject
7.1. The subject gives consent to personal data processing:
- when completing Website forms, by ticking the box below “I agree to the Privacy Policy”;
- when signing an agreement;
- in writing for data authorised for dissemination (photographs, reviews and videos).
7.2. A personal data subject may withdraw consent at any time by sending a notice to info@visit-teriberka.com.
8. Procedure and conditions for processing
8.1. Visit Teriberka LLC uses a mixed method of personal data processing, with and without automated means.
8.2. Only authorised employees who have received instruction may process personal data.
8.3. Data may be transferred to third parties only under an agreement entrusting processing to them and with confidentiality ensured.
8.4. Russian citizens’ data is stored on servers located in the Russian Federation.
8.5. Personal data is retained for no more than 5 years after the processing purpose has been achieved, after which it is destroyed under a commission’s written record.
9. Personal data security measures
Visit Teriberka LLC implements legal, organisational and technical measures:
- appointing a person responsible for personal data processing;
- restricting and recording access to information systems;
- using certified antivirus tools and encryption;
- backups and protection of communication channels;
- storing paper records in secured premises;
- training employees in legal requirements;
- cooperating with GosSOPKA, the state system for detecting, preventing and responding to computer attacks, in security incidents.
10. Rights of personal data subjects
A personal data subject is entitled to:
- obtain information about the processing of their personal data;
- request correction, blocking or destruction of personal data;
- withdraw consent to processing;
- challenge the Operator’s actions before Roskomnadzor or a court.
The Operator must respond to a request within 10 working days, with a possible extension of up to 5 days upon notification to the applicant.
11. Cross-border transfers
The Operator does not carry out cross-border transfers of personal data. All processing operations take place exclusively within the Russian Federation.
12. Destruction of personal data
12.1. Personal data on paper is destroyed by shredding or burning.
12.2. Electronic data is destroyed by formatting or deletion, with a written record prepared.
12.3. Destruction is recorded in a Personal Data Destruction Certificate approved by the General Director.
13. Liability
Persons responsible for breaches of Russian personal data legislation are liable in accordance with applicable Russian law.
14. Contact information
Visit Teriberka LLC
Address: Apartment 28, 3 Komsomolskaya Street, Murmansk, 183038, Russia
Email: info@visit-teriberka.com
Website: https://visit-teriberka.com
The responsible person is appointed by an order of the General Director.
15. Final provisions
15.1. This Policy is approved by the General Director of Visit Teriberka LLC and takes effect on the approval date.
15.2. This Policy remains in force indefinitely until a new revision is approved.
15.3. The current version is available at https://visit-teriberka.com/privacy.