Privacy Policy
1. Personal Data Controller
Controller: Unimerch Tours LLC, registered address: 15 Tverskaya Street, Office 301, Moscow. Email: [email protected], phone: +7 (906) 064-56-65.
This Policy defines the procedure for processing personal data and the measures taken to protect it, in accordance with Federal Law No. 152-FZ "On Personal Data" and the General Data Protection Regulation (GDPR) for residents of the European Union.
2. Data We Collect
When submitting an enquiry form: name, email address, phone number, company name, and message. Without this information, we are unable to process your tour request.
When visiting our website: IP address, user-agent string, pages viewed, and referral source — collected via Umami Analytics (self-hosted, no third-party cookies).
When corresponding by email or messaging applications: the content of messages and any attached files.
3. Purposes of Processing
Business tour organisation: programme selection, visit scheduling, and coordination of dates and NDAs with Chinese companies.
Communication with you: responding to enquiries, confirming requests, and providing tour status updates.
Website improvement: visit analytics are aggregated and do not identify individual users.
Legal obligations: retention of contracts and invoices in accordance with Russian accounting legislation.
4. Legal Bases for Processing
Data subject consent (Art. 6(1)(a) GDPR; Art. 6 of Federal Law No. 152-FZ) — upon submission of the enquiry form.
Performance of a contract (Art. 6(1)(b) GDPR) — when organising a tour at your request.
Legitimate interests (Art. 6(1)(f) GDPR) — for fraud prevention and website diagnostics.
5. Retention Periods
Enquiry data is retained for up to 3 years from the date of last contact, after which it is anonymised.
Contract and invoice data is retained for 5 years in accordance with the Russian Tax Code.
Analytics data is retained in aggregated form with no deletion schedule; individual sessions are not stored.
6. Disclosure to Third Parties
We share your data only with: (a) Chinese companies with whom a meeting is being arranged (name, job title, company, and contact details — solely for the purposes of NDAs and welcome packs), (b) visa services upon your explicit request, and (c) government authorities upon request and in accordance with Russian legislation.
We do not sell your data, share it with advertising networks, or use it for targeting outside this website.
7. Cookies and Analytics
We use only functional cookies (to save your selected locale) and first-party analytics via Umami, hosted on the domain analytics.essentialhustle.dev.
We do not use Google Analytics, Meta Pixel, Yandex.Metrica, or any other third-party tracking tools.
8. Your Rights
You have the right to: obtain a copy of your data, rectify it, request its erasure (right to be forgotten), restrict processing, object to processing, and lodge a complaint with Roskomnadzor or the Data Protection Authority in your country of residence.
To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.
9. Data Security
Our database is hosted on servers located within the European Union, with access restricted to SSH key authentication and multi-factor authentication (MFA). All data transmission is conducted exclusively over HTTPS using current TLS certificates. Backups are encrypted.
10. Policy Updates
The current version of this Policy is always available at unimerch-tours.com/privacy. Material changes will be announced by email to clients with whom we are in active correspondence.